LODGED

FEB 12 2018
1

Case Document 1 Filed 02/12/18 Page 1 of 3

FILED . ENTERED

 

RECEIVED

 

m- SEATTLE UNITED STATES DISTRICT COURT FOR THE
Ls. DISTRICT coua WESTERN DISTRICT OF WASHINGTON

 

CLE

HICT OF 
DEPUTY

UNITED STATES OF AMERICA, 
NO. 007,0 

Plaintiff,
INFORMATION

v. Count One: 18 U.S.C. 1343
RAPHAEL A. SANCHEZ, (Wire Fraud)

Defendant. Count Two: 18 U.S.C. 1028A
(Aggravated Identity Theft)

 

 

The United States of America, by and through the United States Department of Justice,
Criminal Division, Public Integrity Section, charges that:
COUNT ONE

Wire Fraud
(Title 18, United States Code Section 1343)

 

Beginning in or about October, 2013, and continuing until on or about October 25, 2017,

in the Western District of Washington, the defendant,
RAPHAEL A. SANCHEZ,

devised and intended to devise a scheme and arti?ce to defraud ?nancial institutions, including
American Express Company, Bank of America Corporation, Capital One Financial Corporation,
Citibank, Discover Financial Services, and JPMorgan Chase Co., by using the personally
identifying information of seven aliens in various stages of immigration proceedings with the
United States Immigrations and Customs Enforcement to obtain money and property by means of

-1 us. DEPARTMENT or JUSTICE
CRIMINAL DIVISION

 

Pursue mrseRrrY SECTION
1400 New YORK AVENUE, NW
WASHINGTON, DC. 20005
(202) 514-1412

 




0? ?4 ON 43- 06.4 ON 1?4 

 

 

Case Document 1 Filed 02/12/18 Page 2 of 3

materially false and fraudulent pretenses, representations, and promises, and in doing so,
transmitted and caused to be transmitted by means of wire communications in interstate or foreign
commerce, writings, signals, and email communications for the purpose of executing such scheme
and arti?ce to defraud; including but not limited to the following email "that SANCHEZ caused to

be sent via interstate wires:

 

DATE OF WIRE DESCRIPTION OF WIRE COMMUNICATION

 

Email message sent from Raphael.Sanchez@ice.dhs.gov to
. Raphael.Sanchez@ice.dhs.gov and 
Apnl 18? 2016 containing a Puget Sound Energy bill addressed to RH. for service
at 3516 South Webster Street Seattle, Washington, and an
image of a United States permanent resident card and the
biographical page of a Chinese passport issued to RH, originating
in Washington and utilizing email servers in West Virginia and
Mississippi

 

 

 

 

All in violation of Title 18, United States Code. Section 1343.

COUNT TWO
Aggravated Identity Theft
(Title 18, United States Code, Section 1028A)

On or about July 5, 2016, in the Western District of Washington, the defendant,

RAPHAEL A. SANCHEZ,

I did knowingly transfer, possess, and use, without lawful authority, a means of identi?cation of

another person, including the name, Social Security number, and birth date of RR, a real person,
during and in relation to a felony violation enumerated in 18 U.S.C. 1028A(c), to wit, wire fraud
in violation of 18 U.S.C. 1343, as charged in Count One of this Information, in violation of 18

U.S.C. 1028A(a)(1). .

- 2 us. DEPARTMENT OF JUSTICE
CRIMINAL DIVISION 
PUBLIC Mom Semen
1400 New YORK Avmrs, NW
WASHINGTON, DC. 20005
(262) 514-1412

 






 

 

Case Document 1 Filed 02/12/18 Page 3 of 3

Respect??ly submitted,

ANNALOU TIROL
ACTING CHIEF
LIC RITY SECTION

?in.

Luke Cass

  
   

 

ica C. Harvey
Trial "Attorneys
Public Integrity. Section

United States Department of Justice
1400 New York Avenue NW, 12th Floor
Washington, DC.

U. s. OF JUSTICE
CRIMINAL DIVISION
PUBLIC INTEGRITY SECTION
1400 NEW YORK Am, NW
WASHINGTON, D. C. 20005 
(202) 5 14-1412