Tuesday, October 24, 2006

Illegal Money Transmitting—Dominic Adu-Gyamfi

A Falls Church, Virginia man has been sentenced to spend 12 months and 1 day in federal prison for operating an illegal money transmitting business in violation of 18 U.S.C.§ 1960.[1] Dominic Adu‑Gyamfi, president of “RediKash,” pled guilty earlier this year to using his company to make wire transfers in excess of $28 million between 2002 and 2005 from the United States to recipients in Thailand, Saudi Arabia, Ghana, England, Hong Kong, China, Cyprus, and India.[2]

Mr. Adu‑Gyamfi received cease‑and‑desist orders from Virginia officials in 2005, but continued to operate his business.[3] On May 16, 2006, Mr. Adu‑Gyamfi entered a guilty plea before Judge Claude M. Hilton in the Eastern District of Virginia.[4] Court records state that Judge Hilton agreed to a reduced sentence in part because the facts indicated that this offense fell outside the “heartland” of the sentencing guidelines for this offense.[5] The standard sentencing range is between 57 and 71 months.[6]

Nonetheless, in a recent U.S. Immigration and Customs Enforcement (ICE) press release, ICE officials used the conviction to play up aspects of the offense that are not, according to court records, relevant to this case.[7] The Virginia Attorney General stated that “these types of operations are frequently used by drug traffickers, alien smugglers, individuals linked to human trafficking as well as by terrorist cells.”[8] Unless the sealed court documents state otherwise, Mr. Adu‑Gyamfi has not been linked legally to any other criminal activities.

18 U.S.C. § 1960
It is a crime to knowingly conduct, control, manage, supervise, direct, or own all or part of an unlicensed money transmitting business. The term “unlicensed money transmitting business” means a money transmitting business which affects interstate or foreign commerce and is either unlicensed, noncompliant with registration requirements, or supports other criminal activities.

Penalties include imprisonment for up to 5 years, a fine, or both.



[1] Virginia Man Sentenced to Jail for Operating Illegal Money Transmitting Business that Moved $28 Million, ICE Press Release, Oct. 20, 2006 [hereinafter ICE].
[2] Id.
[3] Id.
[4] U.S. v. Adu‑Gyamfi, 1:06-cr-00206-CMH, Minute Entry (unnumbered) (E.D. VA, May 16, 2006).
[5] U.S. v. Adu‑Gyamfi, 1:06-cr-00206-CMH, Minute Entry (unnumbered) (E.D. VA, Oct. 20, 2006).
[6] U.S. Sentencing Guidelines Manual § 2S1.3 (2005).
[7] ICE supra note 1.
[8] ICE supra note 1.