Case 7:20-cr-00589 Document 1 Filed on 02/22/20 in TXSD Page 1 of 2 A0 9 (Rev. 1 Ill l) Criminal Complaint UNITED STATES DISTRICT COURT for the FEB 2 230.20 Southern District of Texas a Ow?: Southern Bistro: or 't?exas FILE 3 David J. Bradley. Clerk United States of America AA v. .. Kevrn Mohammad - 003: 1997 Citizenship: Mexico 3 Defendant(s) . CRIMINAL COMPLAINT I, the complainant in this case, state that the following is true to the best of my knowledge and belief. On or about the date(s) of February 21. 2020 in the county of Hidalgo in the Southern District of Texas the defendant(s) violated: Code Section Ojj?ense Description 31 USC 5332 Knowingly and intentionally conceals over $10,000.00. that is. approximately $214,000.00 in United States Currency, on the person of such individual or in any conveyance, article of luggage, merchandise or other container. and transports or transfers or attempts to transport or transfer said currency from a place within the United States to a place outside the United States. that is, the United Mexican States. with the intent to evade a currency reporting requirement. This criminal complaint is based on these facts: See Attachment Continued on the attached sheet. Isl Jorge Rodriguez Complainant 's signature Submitted by reliable electronic means. sworn -to and attested to telephonically per Fed. R. Jorge Rodriguez, HSI Task Force Of?cer Cr. and probable cause found on: Printed name and title Date: 0222/2020 3.52 p..m . 0% . . Judge signature City and state: McAIlen, Texas US. Magistrate Judge Peter Printed name and title Case 7:20-cr-00589 Document 1 Filed on 02/22/20 in TXSD Page 2 of 2 Attachment . I, Jorge Rodriguez, am a Task Force Of?cer of the United States Homeland Security Investigations (H31) and have knowledge of the following facts. The facts related in this attachment do not re?ect the totality of information knovim to'me or other agents/of?cers, merely the amount needed to establish probable cause. I do not rely upon facts not set forth herein in reaching my conclusion that a complaint should be issued, nor do I request that this Court rely upon any facts not set forth herein in reviewing this attachment in support of the complaint. 1. 0 On February 2020, Homeland Security Investigations in McAllen, Texas, (HSI McAllen) received a request for investigative assistance ?from the US. Customs and Border Protection (CBP) Of?ce of Field Operations at the Anzalduas Port of Entry (POE) in Mission, Texas. CBP Of?cers (CBPOs) detained Kevin Mohammed TAPIA-MARTINEZ (hereafter TAPIA), a citizen of Mexico, while attempting to exit the United States into Mexico with approximately $214,000.00 in US currency concealed within aftermarket constructed concealed compartments in the vehicle he was driving. During primary outbound inspection, CBPOs obtained a negative oral declaration for?drugs, weapons and currency over $10,000.00 from TAPIA claimed to be traveling from McAllen, Texas to Reynosa, Tamaulipas, Mexico. referred TAPIA to secondary inspection for an intensive examination. . During secondary inspection and a physical search of the vehicle, discovered US currency hidden in a non-factory manufactured compartments located in the rear wheel area and the front frame rails. The stacks of currency were counted, with an amount of approximately $214,000.00. HSI Special Agents responded to the Anzaldua's POE to assist in the investigation. HSI Special Agents and Task Force Of?cers interviewed TAPIA, who admitted to smuggling bulkcash in excess of $10,000 dollars in US currency. TAPIA stated he knew the reporting requirements on monies over $10,000 dollars: