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UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY
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UNITED STATES OF AMERICA : CRIMINAL COMPLAINT

v. :

ELIAHU BEN HAIM : Mag. No. 09-3612

I, Robert J. Cooke, being duly sworn, state that the following is true and correct to the
best of my knowledge and belief.

From in or about June 2007 to in or about February 2009, in Monmouth County, in the
District of New Jersey, and elsewhere, defendant ELIAHU BEN HAIM did:

knowingly and willfully conspire with others to conduct and attempt to conduct financial
transactions involving property represented to be the proceeds of specified unlawful activity,
specifically, bank fraud, bankruptcy fraud and trafficking in counterfeit goods, with the intent to
conceal and disguise the nature, location, source, ownership, and control of the property believed
to be proceeds of specified unlawful activity, contrary to Title 18, United States Code, Section
1956(a)(3).

In violation of Title 18, United States Code, Section 1956(h).

I further state that I am a Special Agent with the Federal Bureau of Investigation, and that this
complaint is based on the following facts:

SEE ATTACHMENT A

continued on the attached page and made a part hereof.

_______________________________
Robert J. Cooke, Special Agent
Federal Bureau of Investigation

Sworn to before me and subscribed in my presence,

July , 2009, at Newark, New Jersey

HONORABLE MARK FALK _______________________________

UNITED STATES MAGISTRATE JUDGE Signature of Judicial Officer
 Attachment A

I, Robert J. Cooke, am a Special Agent with the Federal

Bureau of Investigation (“FBI”). I have personally participated
in this investigation and am aware of the facts contained herein,
based upon my own participation in this investigation, as well as
information provided to me by other law enforcement officers.
Because this Attachment A is submitted for the limited purpose of
establishing probable cause, I have not included herein the
details of every aspect of this investigation. Statements
attributable to individuals contained in this Attachment are
related in substance and in part, except where otherwise
indicated. All contacts discussed herein were recorded, except
as otherwise indicated.

1. At all times relevant to this Complaint, defendant

Eliahu “Eli” Ben Haim (“defendant BEN HAIM”), a resident of
Elberon, New Jersey, was the principal rabbi of Congregation Ohel
Yaacob, a synagogue located in Deal, New Jersey. Defendant BEN
HAIM operated several charitable tax-exempt organizations in
conjunction with his synagogue, including one called Congregation
Ohel Eliahu (hereinafter, “COE”). A check with the New Jersey
Department of Banking and Insurance and the New York State
Department of Banking has revealed that defendant BEN HAIM does
not hold a license to transmit or remit money.

2. At all times relevant to this Complaint:

(a) There was a coconspirator with the initials I.M.

(hereinafter, “Coconspirator I.M.") who was an individual based
in Israel. Coconspirator I.M. operated as defendant BEN HAIM’s
principal source for cash. During the course of the
investigation, defendant BEN HAIM indicated that he would wire
the proceeds of checks made payable to his charitable
organization, COE, to Coconspirator I.M. who would, in turn, for
a fee of approximately 1.5 percent, make cash available to
defendant BEN HAIM at various locations, typically in Brooklyn,
New York. Defendant BEN HAIM would in turn provide this cash to
many of those who had provided him with checks made out to his
charitable organization in return for which defendant BEN HAIM
retained a significant commission, typically ten percent. A
check with the New Jersey Department of Banking and Insurance and
the New York State Department of Banking has revealed that
Coconspirator I.M. does not hold a license to transmit or remit
money;

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 (b) There was a coconspirator using the name Schmulik Cohen
(hereinafter, “Coconspirator Cohen”) who resided in Brooklyn.
Coconspirator Cohen received large quantities of cash from
unknown individuals at the direction of Coconspirator I.M., and
then provided this cash to other individuals, including defendant
BEN HAIM. During the course of the investigation, the CW
retrieved cash from Coconspirator Cohen on behalf of defendant
BEN HAIM on multiple occasions. Defendant BEN HAIM also related
that he personally picked up cash from Coconspirator Cohen at
Coconspirator Cohen’s residence and that Coconspirator Cohen had
likewise traveled to defendant BEN HAIM’s residence to deliver
large quantities of cash. A check with the New Jersey Department
of Banking and Insurance and the New York State Department of
Banking has revealed that Coconspirator Cohen does not hold a
license to transmit or remit money;

(c) There was a coconspirator named Arye Weiss

(hereinafter, “Coconspirator Weiss”) who resided in Brooklyn.
Much like Coconspirator Cohen, Coconspirator Weiss received large
quantities of cash from unknown individuals at the direction of
Coconspirator I.M., and then provided this cash to other
individuals, including defendant BEN HAIM. During the course of
the investigation, the CW retrieved cash from Coconspirator Weiss
on behalf of defendant BEN HAIM on multiple occasions. Defendant
BEN HAIM also related that he personally picked up large
quantities of cash from Coconspirator Weiss's residence several
times. A check with the New Jersey Department of Banking and
Insurance and the New York State Department of Banking revealed
that Coconspirator Weiss does not hold a license to transmit or
remit money; and

(d) There was a cooperating witness (the “CW”) who had

been charged in a federal criminal complaint with bank fraud in
or about May 2006. Pursuant to the FBI’s investigation and under
its direction, the CW from time to time represented that the CW
purportedly was engaged in illegal businesses and schemes
including bank fraud, trafficking in counterfeit goods and
concealing assets and monies in connection with bankruptcy
proceedings.

3. On or about June 26, 2007, defendant BEN HAIM met with

the CW at defendant BEN HAIM’s residence in Elberon. During the
ensuing meeting, defendant BEN HAIM accepted a $50,000 check,
drawn upon an account for a fictitious company set up by the FBI
for the purpose of enabling the CW to launder money represented
to be the proceeds of illegal activities. The check was made
payable to COE, defendant BEN HAIM’s charitable organization, and
was provided to defendant BEN HAIM with the expectation that the

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proceeds would be returned to the CW at a later date, minus a ten
percent fee to be retained by defendant BEN HAIM. The CW
represented that the proceeds of this $50,000 check came from
“that guy who was holding, uh, my, uh, money for me on that
Florida insurance, uh, scam that I did.” In response to that
statement, defendant BEN HAIM asked “[a]nd you need forty-five
thousand?” The CW responded in the affirmative, prompting
defendant BEN HAIM to reply “[o]kay . . . Give me a couple days.”
During the same conversation, defendant BEN HAIM described
Coconspirator I.M.’s activities in the following manner: “He
washes money for people [u/i]. He washes money for people here .
. . He gives me a check. I deposit it . . . from a third party .
. . He give me –- I deposit it. I wire it to him. He gives me,
uh, like, one percent.” Defendant BEN HAIM further stated that
he had known Coconspirator I.M. for four to five years. At the
conclusion of the conversation, the CW mentioned that the CW
would be in Brooklyn the following Thursday, and offered to pick
up cash on defendant BEN HAIM’s behalf. Defendant BEN HAIM
seemed hesitant because he anticipated that it would be a large
amount of money. The CW asked if the amount would be “half a
mill,” prompting defendant BEN HAIM to respond “yeah.”

4. On or about June 28, 2007, defendant BEN HAIM met with

the CW at defendant BEN HAIM’s residence in Elberon. During the
ensuing conversation, defendant BEN HAIM accepted from the CW a
bank check in the amount of $50,000 made payable to COE.
Defendant BEN HAIM was informed by the CW that this check
represented the proceeds of what the CW termed “that insurance,
uh, scam deal from Florida.” The CW also purported to defendant
BEN HAIM that the CW had a great deal of money available to the
CW because the CW was able to shield from the CW’s ongoing
bankruptcy court proceedings the money that the CW was earning on
property deals involving “silent partnerships.” The CW explained
that “this way, you know, they give me a check or a bank check to
you. They get a write off. It’s good for them. I get the money
back. So this way there’s no trace, you know, through you, and
it works out for everybody. That’s why I have a lot of money
coming through.” Defendant BEN HAIM was further informed by the
CW that the CW’s reason for laundering the money through
defendant BEN HAIM was “so the court doesn’t know, the
[bankruptcy] trustee doesn’t know, no one knows nothin’.” In
exchange, defendant BEN HAIM gave the CW cash totaling $53,140,
which represented the completion of two money laundering
transactions: $45,000 in cash for a $50,000 check that the CW had
provided to defendant BEN HAIM on June 26, 2007, and $8,100 from
a separate $9,000 check which defendant BEN HAIM had received

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from the CW the previous day.1 As he collated the cash to give
to the CW, defendant BEN HAIM ran the bills through a cash-
counting machine. Defendant BEN HAIM also mentioned that he owed
another individual $495,000. This individual, according to
defendant BEN HAIM, had wired money from Hong Kong to Israel, and
stated that “he has money in Hong Kong from his –- the kickbacks
from the factories.” Defendant BEN HAIM also further described
the activities of Coconspirator I.M. in the following terms: “the
head contact’s in Israel . . . He has different people, he has, .
. . he has a hundred cus-, no customer in New York [u/i] money in
Israel [u/i] real estate investments, they, they want to hide
their money. They don’t want it to show. So they give the cash
here to him and he gives me the cash . . . You see the merry-go-
round? This guy’s been doing it for 20, 30 years.” Defendant
BEN HAIM also indicated that he would pick up cash, as
coordinated by Coconspirator I.M., at locations in Brooklyn. The
CW offered to pick up the cash that defendant BEN HAIM
anticipated would be available to him the following week.

5. On or about July 2, 2007, defendant BEN HAIM met with

the CW at defendant BEN HAIM’s residence in Elberon. During the
meeting, defendant BEN HAIM gave the CW approximately $65,600 in
cash to complete earlier transactions involving the proceeds of
money laundering. Of the monies provided to the CW,
approximately $45,000 represented the proceeds from the $50,000
check provided by the CW on June 28, 2007, minus the ten percent
fee kept by defendant BEN HAIM. Defendant BEN HAIM noted that “I
owe you 45 [thousand],” in reference to the $50,000 check
provided on June 28, 2007. In addition, $20,250 of the cash
given by defendant BEN HAIM was in anticipation of a $22,500
check, which the CW was to provide drawn upon the account of a
charitable organization administered by another money launderer,
Rabbi Saul Kassin. The CW promised to bring defendant BEN HAIM
this check for “twenty-two-five,” and also stated that the CW
would have another 100 thousand dollar bank check. Defendant BEN
HAIM agreed to provide the CW with $90,000 in cash in exchange
for the $100,000 check. During the meeting, defendant BEN HAIM
also mentioned that another customer had sent him “200
[thousand]” that morning, and that he was expecting another check
in the near future in the amount of $450,000.

6. On or about July 10, 2007, defendant BEN HAIM met with

the CW at defendant BEN HAIM’s residence in Elberon. During the
meeting, the CW provided a plastic bag containing approximately

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An additional $40.00 was included in the sum of cash
provided to CW on this date.

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$98,500 in cash which the CW had picked up from a location in
Brooklyn earlier that day at the direction of defendant BEN HAIM.
In addition, defendant BEN HAIM accepted from the CW a check in
the amount of $100,000 made payable to COE. In exchange,
defendant BEN HAIM gave the CW approximately $89,850 in cash,
explaining that he was withholding money from the $90,000 that he
normally would have paid because he had inadvertently overpaid
the CW during the July 2, 2007 transaction.

7. On or about August 1, 2007, defendant BEN HAIM met with

the CW in defendant BEN HAIM’s vehicle, as it was parked in front
of a residence in Deal. During the meeting, defendant BEN HAIM
accepted from the CW a bank check made payable to COE. The CW
described the bank check, which was in the amount of $75,000, as
follows: “this is 75 from that bank schnookie deal. And I have
one more 75 from him and that’s the –- we got a half million from
a bank . . .” Defendant BEN HAIM wondered what he should tell
authorities “[i]f they ask me where did you get this check from?”
After the CW again referred to the check as stemming from a
fraudulent loan, defendant BEN HAIM answered his own question by
stating that he would tell authorities that “he mailed me an
anonymous donation . . . .” During the same conversation,
defendant BEN HAIM provided further details about Coconspirator
I.M.’s laundering operation and referred to a specific individual
as Coconspirator I.M.'s partner, and further stated that “there’s
six people involved in this thing.” Defendant BEN HAIM also
referred to the pick ups of cash in New York City, and the CW
offered to pick up the cash for defendant BEN HAIM. When the CW
asked whether it would be the same guy from whom the CW had
previously received money several weeks earlier, defendant BEN
HAIM stated that the pickup “[c]ould be [in] Queens, could be a
hotel in Manhattan, it could be anywhere. Lately, it’s been Boro
Park.”

8. On or about August 6, 2007, defendant BEN HAIM met with

the CW at defendant BEN HAIM’s residence in Elberon. During the
ensuing conversation, defendant BEN HAIM accepted a bank check in
the amount of $50,000 from the CW. As with previous checks, this
bank check was made payable to COE. The CW described the check
as follows: “This is a check for, uh, fifty thousand from that,
uh, bank, uh, schnookie deal.” On this occasion, defendant BEN
HAIM gave the CW approximately $67,500 in cash to complete the
money laundering transaction from August 1, 2007, during which
the CW had provided defendant BEN HAIM with the aforementioned
$75,000 check. The CW agreed to pick up cash for defendant BEN
HAIM the following day, and defendant BEN HAIM, referring to the
person from whom the CW would pick up the cash, stated “[h]e sits
there all day, and he’s going to have it tonight. So tomorrow,

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you can get it.” Defendant BEN HAIM indicated that he had picked
up cash from numerous individuals over the years, stating that
“[i]n the five years [I’m] with [Coconspirator I.M.], maybe I saw
over a hundred different people.” Defendant BEN HAIM also
informed the CW that Coconspirator I.M. wanted defendant BEN HAIM
to open an account in Geneva, Switzerland, through which he would
launder cash for one specified individual. Defendant BEN HAIM
explained that Coconspirator I.M. wished him to deposit as much
as $30 million per year into this account, for which defendant
BEN HAIM would earn approximately $1.5 million annually.

9. On or about October 31, 2007, defendant BEN HAIM met

with the CW in defendant BEN HAIM’s vehicle, which was parked
outside a location in Deal. During the meeting, defendant BEN
HAIM accepted two checks from the CW –- both of which were made
payable to COE as part of money laundering transactions. One of
these checks was a bank check in the amount of $50,000, while the
other check was in the amount of $22,500 and drawn upon the
account of a charitable organization administered by another
money launderer, Rabbi Saul Kassin. During the meeting,
defendant BEN HAIM remarked that he was currently low on cash,
and that it was difficult to get a sufficient supply of cash on a
timely basis from Coconspirator I.M. to keep pace with the demand
of his customers. Defendant BEN HAIM remarked that “four, five
years I’m doing this with this guy. I know at the end of the
year it’s tight.” Defendant BEN HAIM related that prior to his
dealings with Coconspirator I.M., he had moved cash through
another individual, but stated that “they caught him laundering .
. . he got a slap on the wrist.” Defendant BEN HAIM indicated
that this individual was finishing a ten-month sentence that he
was serving at F.C.I. Otisville. Subsequently, defendant BEN
HAIM complained that he was “lucky” if he could move one to two
million dollars a year at present. He remarked that “the most I
ever did was seven to eight” million dollars in a year, and
indicated that he earned “a million dollars a year” during that
period.

10. On or about December 20, 2007, defendant BEN HAIM met

with the CW at defendant BEN HAIM’s residence in Elberon. During
this meeting, defendant BEN HAIM received approximately $118,000
in cash from the CW which the CW had picked up in Brooklyn from
Coconspirator Cohen earlier that day at defendant BEN HAIM’s
direction. Defendant BEN HAIM also accepted a bank check from
the CW in the amount of $50,000 made payable to COE as part of a
money laundering transaction. When the CW handed the check to
defendant BEN HAIM, the CW stated that “this is a fifty I picked
up yesterday from Brooklyn. This is on that [] Bank schnookie
deal. . . The guy owes me another hundred [thousand] on that, but

6
not till after the New Year.” The CW also informed defendant BEN
HAIM that “I should have another check today . . . for twenty-
five [thousand],” a reference to a money laundering deal that the
CW hoped to consummate with another money launderer, Rabbi Saul
Kassin, later that day. This prompted defendant BEN HAIM to
place a call to Coconspirator I.M., and, upon conclusion of that
call, defendant BEN HAIM stated that “[h]e’s gonna let me know”
whether there would be a cash pickup in Brooklyn later that day.
In exchange for the $50,000 check and as payment on a prior
laundering deal, defendant BEN HAIM counted out approximately
$55,000 from the cash that the CW had delivered and gave it to
the CW. Defendant BEN HAIM stated that he was unable at that
time to provide any additional cash to the CW to complete other
prior deals, as he needed the cash for two other individuals
bringing him checks for $52,000 and $28,000, respectively.

11. On or about January 14, 2008, defendant BEN HAIM met

with the CW at defendant BEN HAIM’s residence in Elberon. During
this meeting, defendant BEN HAIM accepted a cashier’s check from
the CW in the amount of $100,000 made payable to COE. When the
CW handed defendant BEN HAIM the check, the CW stated “[u/i] bank
check there for a hundred thousand. Now that, you have to
understand, that’s from one of the [Bank] schnookie deals. I
have a guy who owes me a half a million dollars. This is a
hundred. I have four hundred thousand dollars more.” The CW
inquired whether defendant BEN HAIM would be able to launder that
latter amount over “the next couple of weeks,” prompting
defendant BEN HAIM to reply simply “[y]eah.” During the
conversation, defendant BEN HAIM indicated that he had a number
of customers who no longer used him to launder money,
specifically noting one customer who had laundered 1 million
dollars with him in a previous year, and a second who had
laundered 1.5 million in one year. He also indicated that he had
one customer who currently owed him $200,000, while he also had
four customers who wanted cash totaling at least $250,000 “by
tomorrow.”

12. On or about January 20, 2008, defendant BEN HAIM met

with the CW at defendant BEN HAIM’s residence in Elberon. During
the meeting which followed, defendant BEN HAIM accepted a large
sum of cash from the CW contained in a bag which the CW had
picked up in Brooklyn from Coconspirator Cohen the previous day
at the direction of defendant BEN HAIM. It was believed that the
bag contained approximately $300,000 in cash. Defendant BEN HAIM
ran the money provided by the CW through a cash-counting machine.
In addition, defendant BEN HAIM gave the CW approximately $95,200
in cash to complete the money laundering transactions from
December 21, 2007 and January 14, 2008. During this meeting,

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defendant BEN HAIM indicated that he currently owed “about 200
[thousand]” to Coconspirator I.M. for ongoing laundering
transactions. When the CW inquired whether Coconspirator I.M.
was pestering defendant BEN HAIM about this debt, defendant BEN
HAIM indicated that he was not, stating that “[h]e trusts me.”

13. On or about June 13, 2008, defendant BEN HAIM met with
the CW in defendant BEN HAIM’s vehicle outside of a location in
Elberon. During the meeting, defendant BEN HAIM accepted from
the CW a bank check in the amount of $50,000. The CW explained
that the funds from this check were generated from the sale of
counterfeit high-end merchandise manufactured “from my factory in
Brooklyn where I have the–-where I make the bags. I take the
labels . . .” The CW further clarified that “I’m switching the
labels. . . Business is very good. Prada, Gucci, boom, boom,
boom. This is from my profits. This is not–-I put up 400
thousand principal. These are only my profits. Profits from
this, profits from the [bank].” This last remark referred to the
bank fraud scheme involving a particular bank which led to
criminal charges being filed against the CW in 2006. After
defendant BEN HAIM demanded a higher percentage fee than he
normally collected from the CW to conduct the transaction, the CW
complained that “I’m a repeat customer,” and asked “[a]m I your
best customer?” After defendant BEN HAIM responded in a hushed
tone, “[n]o,” the CW replied “[n]o. Why, ‘cause you’ve got guys
who do a million dollars a month . . .?” Defendant BEN HAIM
responded “[n]o, that was once upon a time.” Defendant BEN HAIM
then retrieved a bag from the trunk of defendant BEN HAIM’s car
which contained a box with Power Rangers logos. The box
contained tens of thousands of dollars in bundles of cash, and
defendant BEN HAIM provided the CW with $45,000. The CW
reiterated that the money from the check was “all offshore,” and
noted that “[w]e have the factory. We make the stuff in
Brooklyn, but we offshore it,” and added that “[t]here’s no
trace, no nothing.” By way of explanation, the CW stated that
“[i]t’s offshore. So all the profits are hidden.” After the two
discussed whether defendant BEN HAIM would be doing additional
deals with other individuals in the near future, defendant BEN
HAIM noted, in an apparent reference to Coconspirator I.M., that
“[h]e called me up 14 times. He says ‘I got another 300
[thousand]. You want it?’” Defendant BEN HAIM indicated that he
had declined the offer but then noted that “I have orders for
Sunday . . . I don’t have enough,” thus indicating that the money
remaining from the Power Rangers box would be insufficient for
the customers he would see on Sunday. At the conclusion of the
meeting, defendant BEN HAIM asked the CW if the CW wished to
launder “a hundred [thousand] next week?” The CW responded
“[l]et me see how much, what our profits are next week,” and

8
agreed to contact defendant BEN HAIM if the CW wished to do
another laundering transaction.

14. On or about December 16, 2008, defendant BEN HAIM met

with the CW in defendant BEN HAIM’s vehicle, which was parked at
a location in Deal. During the conversation, defendant BEN HAIM
accepted a bank check made out to COE in the amount of $160,000.
The CW explained that the money represented the profits from the
CW’s handbag business, but explained that the CW’s partner had
provided the CW with less than the CW had hoped because “[e]ven
the knock-off business is tough today.” Defendant BEN HAIM
informed that in exchange for the $160,000 check he would provide
the CW with $130,000 in cash. Defendant BEN HAIM explained that
“I’m putting the order in the pipeline” and related that he had
spoken with his contact - believed to be a reference to
Coconspirator I.M. - the previous Sunday. Defendant BEN HAIM
stated that he expected the pickup of the cash would occur in the
near future in either Williamsburg or Boro Park in Brooklyn.

15. On or about December 30, 2008, defendant BEN HAIM met

with the CW in defendant BEN HAIM’s vehicle, which was parked at
a gas station along Deal Road in Deal. During the meeting,
defendant BEN HAIM provided the CW with approximately $64,850 in
cash as partial payment for the 160,000 check provided by the CW
on or about December 16, 2008. During the conversation,
defendant BEN HAIM was informed by the CW that “things are
picking back up in my, uh, knock-off pocketbook business, my
counterfeit business.” Defendant BEN HAIM also was told that the
money involved in their laundering transaction “is only profits -
principal I keep in there.” Defendant BEN HAIM informed the CW
that he had a lot of “orders” for laundering transactions because
it was near the end of the year, but that some clients wished to
wait until the turn of the year to consummate the transactions.
It is believed that defendant BEN HAIM was referring to the
efforts of some of his customers to select the year during which
they would claim deductions for charitable contributions on their
income tax returns based on the checks provided to defendant BEN
HAIM. During the same conversation, defendant BEN HAIM indicated
that the nearly $65,000 that he was providing to the CW had been
retrieved by defendant BEN HAIM the previous day from
Coconspirator Weiss at Coconspirator Weiss's residence in
Brooklyn.

16. On or about January 18, 2009, defendant BEN HAIM met

with the CW at a location on Ocean Parkway in Brooklyn. During
the ensuing conversation, defendant BEN HAIM and the CW discussed
a potential pickup of approximately $150,000 in Brooklyn during
the following week, the proceeds of which would be used to

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complete the money laundering transaction commenced on December
16, 2008. Defendant BEN HAIM told the CW about “customers from
two, three years ago that are calling me,” and indicated that
“[t]hat’s a signal that the market is tight.” Defendant BEN HAIM
also discussed his source for cash, Coconspirator I.M., and
stated that he spoke to Coconspirator I.M. “[e]very day - every
other day.” Referring to Coconspirator I.M., defendant BEN HAIM
then asked the CW “[d]id you know that he had me in the last 4
years send out wires every time to a different place in the world
to a different name? It’s unbelievable. I never saw anything
like it.” When the CW asked whether defendant BEN HAIM was
referring to different locations in only Israel, defendant BEN
HAIM replied “[n]o, all over the world. . . All over the world.
From Australia to New Zealand to Uganda. I mean [u/i] every
country imaginable. Turkey, you can’t believe it. . . . All
different names. It’s never the same name. . . . Switzerland,
everywhere, France, everywhere, Spain . . . . China, Japan.”
Defendant BEN HAIM also explained that the market for cash was
tight “only in the beginning of the year and the end of the
year.”

17. On or about January 25, 2009, defendant BEN HAIM met

with the CW in defendant BEN HAIM’s vehicle, which was parked at
a location near Norwood Avenue in Deal. During the conversation,
defendant BEN HAIM provided the CW with a plastic bag containing
approximately $20,000 in cash as a further partial payment for
the $160,000 check provided to defendant BEN HAIM on or about
December 16, 2008. Defendant BEN HAIM did not name the person
from whom he had received the cash, and further explained that he
was having difficulty securing cash for his customers. Although
defendant BEN HAIM predicted that in “[a]nother week it’ll be
loosening up,” he explained that at present “[t]he demand [for
cash] is greater than the supply.” He explained that he was
taking advantage of the high demand for cash, noting that “[t]he
bottom line is I got people in the city that are starting to pay
me 20 percent . . .” rather than the 10 percent fee normally
charged by defendant BEN HAIM. Defendant BEN HAIM agreed to
contact the CW when he had secured the remaining $15,000 he owed
the CW.

18. Between in or about June 2007 and in or about February

2009, defendant BEN HAIM engaged in money laundering transactions
with the CW totaling approximately $1.5 million in funds
represented by the CW to involve the proceeds of criminal
activities.

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