Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 1 of 24 PageID 64

UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION

UNITED STATES OF AMERICA

v. CASE NO. 6:24-cr-253-RBD-RMN

MIGUEL ANGEL AGUASVIVAS LIZARDO

NOTICE OF MAXIMUM PENALTIES, ELEMENTS OF OFFENSE,

PERSONALIZATION OF ELEMENTS AND FACTUAL BASIS

The United States of America, by Gregory W. Kehoe, United States Attorney

for the Middle District of Florida, hereby files this Notice of Maximum Penalties,

Elements of Offense, Personalization of Elements and Factual Basis:

ESSENTIAL ELEMENTS

The essential elements of a violation of 18 U.S.C. § 1956(h), Conspiracy to

Commit Concealment Money Laundering, are as follows:

First: Two or more people agreed to try to accomplish a common

and unlawful plan to commit concealment money
laundering, in violation of 18 U.S.C. § 1956(a)(1)(B)(i); and

Second: The Defendant knew about the plan’s unlawful purpose

and willfully joined in it.

The elements of 18 U.S.C. § 1956(a)(1)(B)(i) are:

First: The Defendant knowingly conducted or tried to conduct a

financial transaction;

Second: The Defendant knew that the money or property involved

in the transaction were the proceeds of some kind of
unlawful activity;
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 2 of 24 PageID 65

Third: Money or property did come from an unlawful activity,

specifically importing, distributing, selling, and otherwise
dealing in a controlled substance; and

Fourth: The Defendant knew that the transaction was designed, in

whole or in part, to conceal or disguise the nature,
location, source, ownership, or the control of the proceeds.

PENALTY

The penalty for the offense charged in Count One of the Indictment is a

maximum sentence of 20 years’ imprisonment, a fine of not more than $500,000, or

twice the value of the monetary value or instrument involved, whichever is greater, a

term of supervised release of not more than 3 years, and a special assessment of $100.

Additionally, the defendant must forfeit property, pursuant to 18 U.S.C. §

982(a)(1), as outlined in the Indictment. Among the items that will be forfeited are

the following: at least $1,022,384, representing the funds involved in the offense.

PERSONALIZATION OF ELEMENTS
For Count One, for some period of time from on or about March 2024, and

continuing through at least on or about April 11, 2024, as set forth in the Indictment,

First: Did two or more people agree to try to accomplish a

common and unlawful plan to commit concealment
money laundering, in violation of 18 U.S.C. §
1956(a)(1)(B)(i)?

That is,

a.) Did you knowingly conduct or try to conduct a

financial transaction?

b.) Did you know that the money or property involved

in the transaction were the proceeds of some kind of
unlawful activity?

2
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 3 of 24 PageID 66

c.) Did the money or property come from an unlawful

activity, specifically importing, distributing, selling,
and otherwise dealing in a controlled substance?

d.) Did you know that the transaction was designed, in

whole or in part, to conceal or disguise the nature,
location, source, ownership, or the control of the
proceeds?

Second: Did you know about the plan’s unlawful purpose and
willfully join in it?

FACTUAL BASIS

Beginning no later than in December 2021 and continuing through April 11,

2024, MIGUEL ANGEL AGUASVIVAS LIZARDO (“AGUASVIVAS”) conspired

to launder money and has aided and abetted in money laundering. Specifically, on

several instances, AGUASVIVAS dropped off large amounts of currency to be

laundered in the form of cryptocurrency. On some occasions, an accomplice working

with AGUASVIVAS (“Co-Conspirator 1” and/or “Co-Conspirator 2”) was with

AGUASVIVAS and had ongoing involvement in the money laundering activities. In

total, AGUSAVIVAS personally laundered, or attempted to launder, at least

$1,022,384 1 in drug proceeds, as further detailed below.

The chart below summarizes the key transactions/events involving

AGUASVIVAS and other co-conspirators. For each of these transactions, the

proceeds were obtained from Orlando, Florida before being seized or laundered:

1
The defendant disputes that this is the correct total amount. Specifically, the defendant disputes
that the attempted transaction on February 11, 2022 for $273,244 constituted proceeds of unlawful
activities. The parties intend on litigating this factual dispute at the sentencing hearing.
3
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 4 of 24 PageID 67

Date Agency Transaction Location

April 11, 2024 DEA Pick up of approximately Orlando, Florida
Group $170,000 by K.A., later stolen
12 from K.A. during
carjacking/kidnapping/murder
of K.A.
March 15, 2024 DEA Money Drop by Pembroke Pines,
Group AGUASVIVAS for $111,000 Florida
12 while he was on Facetime with
Co-Conspirator 2.
February 11, 2022 DEA Attempted money drop by Miramar, Florida
Group AGUASVIVAS (with Co-
10 Conspirator 1 in the car) of
$273,244.00; the money was
seized on this occasion by law
enforcement.
November 29, 2021 FBI Money Drop by Miami, Florida
AGUASVIVAS for $210,860
to purchase USDT
cryptocurrency.
December 2, 2021 FBI AGUASVIVAS met with CHS Miami, Florida
and showed the CHS an image
of a brick of cocaine and
offered to provide a sample.
December 6, 2021 FBI Money Drop by Miami, Florida
AGUASVIVAS for $228,340
to purchase USDT
cryptocurrency. Discussion
with CHS about providing
cocaine to the CHS.
December 8, 2021 FBI AGUASVIVAS provided a Miami, Florida
sample of cocaine to the CHS.
December 13, 2021 FBI AGUASVIVAS offered Communications
cocaine to CHS; stated he had only; no meeting.
received kilos of cocaine.
December 14, 2021 FBI Money Drop by Miami, Florida
AGUASVIVAS for $98,940.
December 15, 2021 FBI Money Drop by Miami, Florida
AGUASVIVAS for $100,000
in cash for USDT
cryptocurrency.

4
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 5 of 24 PageID 68

A. April 11, 2024 - Murder of K.A.

On April 11, 2024, at around 12:30 p.m., K.A., the wife of AGUASVIVAS,

left Homestead, Florida, and began driving her white Dodge Durango to 1440

Guinevere, Dr., Casselberry, Florida, to pick up $170,000 from Giovany Joel Crespo

Hernandez (“Crespo Hernandez”). The Guinevere Dr. address is the residence of

Moniscabel Romero-Soto, the girlfriend of Crespo Hernandez.

Around the time that K.A. left her home, Crespo Hernandez called Jordanish

Torres Garcia (“Garcia”). According to cell site data, K.A. arrived at 1440

Guinevere at 5:13 p.m. and left that location around 5:28 p.m. At 5:32 p.m., K.A.

called her husband, AGUASVIVAS. According to AGUASVIVAS, K.A. told him

someone “tapped” her vehicle. He stated that he was on FaceTime with her when

someone came to the window, and he could see that K.A. was scared.

AGUASVIVAS said the phone disconnected and he could not get in contact with

her again. Ultimately, K.A. was carjacked, kidnapped, and killed by Garcia, Kevin

Ocasio Justiniano (“Ocasio”), and others.

At the time of her murder, DEA Group 12 had an active and ongoing money

laundering investigation. Based on that investigation, AGUASVIVAS was a money

courier who would pick up drug proceeds in Central Florida and then drop off

money to an individual he believed to be a money launderer (but who was actually a

DEA undercover agent “UC”) for purposes of converting it to cryptocurrency.

On April 11, 2024, DEA was expecting AGUASVIVAS or Co-Conspirator 2

to drop off money from drug proceeds that were being collected in Orlando. Agents
5
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 6 of 24 PageID 69

later learned that the reason the deal was cancelled was because the proceeds were

stolen during the commission of K.A.’s carjacking and murder.

Phone tolls were later obtained for Crespo Hernandez’s phone number (689)-

255-8173; AGUASVIVAS’s phone number 786-352-0437; and K.A.’s phone number

786-226-2805. The records show that on April 11, 2024, between the hours of 6:14:32

p.m. to 6:54:22 p.m., Crespo Hernandez communicated with Co-Conspirator 1, just

after the armed carjacking and kidnapping occurred and during the time the suspects

would have been in possession of both the victim and her vehicle.

AGUASVIVAS had incoming calls from and outgoing calls to K.A.

throughout the day (including during her drive to Orlando). Around the time that

K.A. arrived in Orlando, AGUASVIVAS called Co-Conspirator 1. AGUASVIVAS

then received and made calls to a phone number subscribed to an individual in the

Dominican Republic (Co-Conspirator-3), who was also being called by Co-

Conspirator 1 around the same time. Around the time K.A. was carjacked,

AGUASVIVAS received and made calls to Co-Conspirator 1 and one to Co-

Conspirator 1’s wife’s phone. Leading up to the time of the carjacking and killing,

Co-Conspirator 1 received and placed calls to AGUASVIVAS and Co-Conspirator-

3, who was also calling AGUASVIVAS.

As part of the carjacking/killing investigation, law enforcement interviewed

AGUASVIVAS on April 12, 2024, who provided authorities with his cell phone and

written consent to search his phone. AGUASVIVAS stated during the interview that

he would get paid to invest other people’s money in cryptocurrency. A review of

6
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 7 of 24 PageID 70

AGUASVIVAS’s cellular phone revealed a conversation between AGUASVIVAS

and Co-Conspirator 1 about a drug transaction for cocaine on January 26, 2024.

B. Interview of Cooperating Witness-1

In April 2024 and September 2024, DEA Group 12 interviewed Cooperating

Witness-1, who was a close friend of K.A. CW-1 confirmed that K.A. was engaged

in money laundering at the direction of AGUASVIVAS, Co-Conspirator 1 and Co-

Conspirator-3. CW-1 reports that AGUASVIVAS was historically involved in drug

distribution. Immediately following the February 11, 2022 money rip (referenced

below and completed by DEA Group 10), AGUASVIVAS called K.A. and told her

to go get the money and money counters from the residence they shared. This call

was made in the presence of CW-1. CW-1 observed luggage containing loose cash

and two large vacuumed sealed packages, which CW-1 believed contained over

$200,000. At some point, AGUASVIVAS met with someone in a black BMW sedan

and gave the luggage to that person.

K.A. told CW-1 that she would get paid $1,000 per trip to pick up money.

CW-1 stated that K.A. had made over ten trips to the Orlando area to pick up

money, all of which were drug proceeds. K.A. used a black Samsung Metro Phone

to communicate with the people she would meet with. The same phone was also

used by AGUASVIVAS. According to CW-1, AGUASVIVAS and K.A. were

separated at the time of her death and AGUASVIVAS was helping K.A. pay rent by

giving her the chance to act as a courier and make $1,000 per trip.

7
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 8 of 24 PageID 71

CW-1 reports that Co-Conspirator 1 works for AGUASVIVAS in the money

laundering operation. In the days after K.A.’s death, CW-1 was with Co-Conspirator

1 when a news story came on about her killing and Co-Conspirator 1 stated, “And to

think that was my trip.” Co-Conspirator 1 also stated, “if I say the whole truth, I’d

have to put people in the middle of it” and “it hurts me, it’s [redacted], but nothing

obligated her.”

C. March/April 2024 – DEA Group 12’s Money Laundering Investigation

In March and April 2024, DEA Miami Task Force Group 12 were

investigating a ring of money launderers who would drop off large amounts of

currency to be laundered back to a drug cartel in Colombia in the form of

cryptocurrency. In this operation, a DEA undercover (“UC”) would act as a money

launderer for the cartel and accept a “contract” to receive a delivery of currency.

Communications during this operation, including acceptance of the contract,

occurred using encrypted messaging applications.

On March 11, 2024, the source was contacted by a money-launderer via

WhatsApp communication. The source offered to receive and launder drug proceeds

in the amount of $180,000 in Miami, Florida for a negotiated commission of 0.5

percent. The source was directed to provide the money-launderer with a Miami

based undercover number, along with the verbal code of “Manuel de Parte de

Hugo.” The money launder was also provided a serial number from a one-dollar bill

(A03680170A). The information was relayed through the source to be exchanged

upon the delivery of the currency.

8
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 9 of 24 PageID 72

At approximately 2:00 p.m., the UC received a phone call to meet with an

unidentified male, later identified as Co-Conspirator 2, at the Chase Bank parking lot

located at 14916 Pines Blvd., in Pembroke Pines, Florida. Shortly thereafter, the UCs

arrived at the meet location, and waited for Co-Conspirator 2 to arrive.

At approximately 3:00 p.m., Co-Conspirator 2 arrived at the location and

parked his vehicle on the driver side of the UC vehicle. Co-Conspirator 2 approached

the UC vehicle occupied by the two DEA UCs. UC-1 on the driver side greeted Co-

Conspirator 2 and asked him to confirm the last four numbers of the token (serial

number of the US dollar bill), which Co-Conspirator 2 stated “0170A.” Moments

after, Co-Conspirator 2 went back into his vehicle to retrieve a black bag with a navy-

blue shoebox inside of it from his rear passenger-side seat. Upon returning to the UC

vehicle, Co-Conspirator 2 handed the black bag to UC-1 on the driver side of the

vehicle through the window. UC-1 asked Co-Conspirator 2 to confirm the amount,

which Co-Conspirator 2 stated that it was “180.” Shortly thereafter, UC-1 gave the

bag to UC-2, who took control of the black bag, looked inside of it, opened the navy-

blue shoe box, and observed an undetermined amount of USC. UC-1 asked Co-

Conspirator 2 to write the amount that was in the shoebox on the dollar so he (the

UC-1) could take a picture of it for confirmation. Co-Conspirator 2 agreed and wrote

“$180” and “3/11” on the token. The currency was bundled in different

denominations of 5s, 10s, 20s, and 100s. A white piece of paper with the makeup of

denominations was placed on top of one of the bundles.

9
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 10 of 24 PageID 73

• March 15, 2024 – Money Drop by AGUASVIVAS for $111,000

On March 15, 2024, a UC, wearing an audio and video recording device,

arranged to pick up cash at a parking lot located in Pembroke Pines, Florida. At

approximately 2:43 p.m., the UC arrived at the vicinity of Chase Bank near Pines

Blvd and SW 149th Avenue, in Pembroke Pines, Florid. At approximately 2:45 p.m.,

AGUASVIVAS arrived in a White BMW SUV at the meet location. AGUASVIVAS

greeted the UC and engaged in social conversation. AGUASVIVAS asked the UC to

confirm the token (serial number of the US dollar bill), which the UC confirmed that

the last four numbers of the token were “6794G.”

The UC noticed that AGUASVIVAS was on a Facetime phone call with Co-

Conspirator 2. AGUASVIVAS remained on the call with Co-Conspirator 2 during

the entire transaction, including when AGUASVIVAS gave the cash to the UC.

AGUASVIVAS gave the UC a shopping bag, which contained an undetermined

amount of cash. The UC asked AGUASVIVAS how much currency was inside the
10
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 11 of 24 PageID 74

bag, which he (AGUASVIVAS) stated that there was “111” and that the money was

very well counted. The UC put the bag in the UC vehicle and AGUASVIVAS

departed.

Once AGUASVIVAS left the premises, the UC awaited instructions that the

area was clear. Subsequently, the UC departed the area and a Broward County

Sheriff's K-9 Narcotics handler and his K-9 Zoey conducted a dog sniff of the money

container, which alerted positive to the presence of narcotics.

Subsequently, the UC took a .5% fee that was negotiated with the DTO’s

money broker, deposited the remainder of the cash into an undercover bank account,

and then transferred the money to a cryptocurrency wallet provided by the money

broker. Images captured from the UC video recorder show AGUASVIVAS during

the money drop and the drug proceeds that were laundered:

11
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 12 of 24 PageID 75

• April 3, 2024 – Money Drop by Co-Conspirator 2 for $160,000

On April 3, 2024, the source was contacted by a Colombia based money-

launderer via WhatsApp communication, the source offered to receive and launder

drug proceeds in the amount of $160,000.00 in Miami, Florida, for a negotiated

commission of 1 percent commission. The source was directed to provide the

launderer with a Miami based undercover number along with the verbal code of

“Richard de parte de William.” The launderer was also provided a serial number

from a one-dollar bill (L25020761F). The information was relayed through the

source to be exchanged upon the delivery of the currency.

On the same day, at approximately 11:05 a.m., the UC arrived at 1560

Sawgrass Corporate Parkway, Sunrise, Florida, meet location and entered the lobby

area. A few minutes later, the UC exited the building and made contact with Co-

Conspirator 2 at the front entrance. Co-Conspirator 2 delivered $160,000 in drug

proceeds. The UC retrieved the large shopping bag from Co-Conspirator 2 and

walked back inside the building.

The CHS was then informed by DEA agents that $160,000 was picked up to

relay the amount to the launderer. On the same date, the CHS was directed to send

the suspected drug proceeds through a USDT cryptocurrency wallet in order to pay

out the currency in Colombia masked through trade-based commodities and/or

services unitizing the Black-Market Peso Exchange (BMPE) and would use this

financial mechanism to facilitate compensation to the drug trafficking organization

in Colombia.
12
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 13 of 24 PageID 76

• May 3, 2024 – Co-Conspirator 2 Met with UC to Negotiate 15 Kilo

Cocaine Purchase

From March 11, 2024 through May 3, 2024, the UC had several

communications (WhatsApp/Signal calls and texts) with Co-Conspirator 2 related to

a drug trafficking venture in South Florida. During these communications, Co-

Conspirator 2 told the UC that he was away in the Dominican Republic, as he was

looking for “LUNCHES” because he was “DRY,” and that his customers were

“HUNGRY.” Co-Conspirator 2 also stated to the UC that he was looking to

purchase large amounts of cocaine, as he can manage large quantities. Moreover,

Co-Conspirator 2 told the UC that he (the UC) should know how much he (Co-

Conspirator 2) can handle, as he (Co-Conspirator 2) dropped a large amount of cash

to the UC when they first met.

During these communications, Co-Conspirator 2 asked the UC for the price

per kilogram of cocaine, which the UC stated that it was ranging between 13 - 13.5

($13,0000 - $13,5000 USD). Co-Conspirator 2 told the UC that the price was fair and

that he would be returning on Thursday (May 2, 2024) to Miami, Florida, and that

he would be able to meet the UC on Friday (May 3, 2024) to discuss details of a

possible drug trafficking venture.

On May 3, 2024, Co-Conspirator 2 met with a DEA UC in Coral Gables,

Florida, to negotiate the purchase of 15 kilograms of cocaine.

13
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 14 of 24 PageID 77

• June 5, 2024 – Co-Conspirator 2 Arrested with 10 Kilos of Cocaine

On June 5, 2024, Co-Conspirator 2 was arrested in the Southern District of

Florida following a traffic stop during which he was found in possession of 10

kilograms of cocaine and $191,700. On June 20, 2024, Co-Conspirator 2 was

indicted for conspiracy to possess with intent to distribute a controlled substance, and

possession with intent to distribute a controlled substance, in violation of 21 U.S.C.

§§ 846 and 841(a)(1); and conspiracy to engage in money laundering, and money

laundering, in violation of 18 U.S.C. §§ 1956(h) and (a)(l)(B)(i). One of the money

laundering counts was based on AGUASVIVAS being on a FaceTime call with Co-

Conspirator 2 throughout the duration of the March 15 cash delivery to the UC.

14
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 15 of 24 PageID 78

D. February 2022 - DEA Group 10 Money Laundering Investigation

In or around February 2022, the DEA Miami Field Division Task Force

Group 10 (TFG-10) was investigating a drug trafficking organization in the Miami

area that was laundering drug proceeds by purchasing cryptocurrency. During the

months of January and February 2022, a federal task force officer, acting in an

undercover capacity (the “UC”), negotiated with money broker Co-Conspirator 4 to

receive bulk cash and exchange it into crypto currency. On February 11, 2022, the

UC coordinated with Co-Conspirator 4 to have a money courier meet with the UC

and Co-Conspirator 4 to deliver bulk cash.

a. February 11, 2022 Seizure from AGUASVIVAS and Co-Conspirator 1

On February 11, 2022, the UC received a text from Co-Conspirator 4 advising

he was on his way to Miami to meet up with money courier who wanted to

exchange bulk cash into crypto currency. Co-Conspirator 4 said he was going to

verify the courier had the cash on hand before meeting with the UC.

At approximately 11:25 a.m., Co-Conspirator 4 texted the UC to advise he

was about 2 minutes away from the meeting location with the courier. At

approximately 11:51 a.m., the UC received a text from Co-Conspirator 4 stating, “I

have eyes on the doe,” confirming that he had seen the bulk cash from the courier.

At 12:04 p.m., the UC received a phone call from Co-Conspirator 4 to see if the UC

was nearby. Co-Conspirator 4 also told the UC that he (Co-Conspirator 4), and the

buyer/courier would be the ones going up to the UC’s office to conduct the

transaction.
15
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 16 of 24 PageID 79

At approximately 12:15 p.m., the UC arrived at the parking lot. The UC was

told that the buyers/couriers were ready. The UC told Co-Conspirator 4 that the

office was in the building behind the business and for the couriers to follow them.

The courier proceeded to walk towards a black BMW that was in the parking lot and

met with the driver (later identified as AGUASVIVAS). Co-Conspirator 1 was a

passenger in the car with AGUASVIVAS. Soon after, AGUASVIVAS asked the UC

if he was a cop. The UC redirected the question to AGUASVIVAS and said that Co-

Conspirator 1 looked like cop. Moments later, Enforcement Group 10 Agents and

TFOs approached all parties. Subsequently, $273,244 was seized from the BMW.

AGUASVIVAS was observed driving a 2011 black BMW 328, to the meeting

location with Co-Conspirator 1. DEA seized $273,244.00, two firearms, three

cellular phones and a BMW from AGUASVIVAS. During the search of

AGUASIVAS’s BMW, approximately $273,244.00 was located inside a backpack in

the rear seat behind the driver side of the BMW and two shoe boxes of bundled cash

secured with rubber bands located in the trunk of the BMW.

E. November/December 2021 – FBI Money Laundering Investigation

In November and December 2021, AGUASVIVAS conducted money drops to

FBI CHS’s during the course of an FBI investigation.

• November 29, 2021 – Money Drop by AGUASVIVAS for $210,860

On November 28, 2021, an FBI CHS was contacted by and arranged a meet

through a Colombian based money broker to purchase approximately $210,000 in

16
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 17 of 24 PageID 80

cryptocurrency. The transaction was to take place at the Intercontinental Hotel in

downtown Miami on November 29, 2021.

On November 29, 2021, the CHS received Whatsapp messages and calls from

telephone number +57-310-707-6495, Alex LNU. ALEX’s Whatsapp profile

revealed a landscape photograph and the name “Crypto Deals Miami.” ALEX told

the CHS that the messenger had departed and asked for a “selfie” of CHS’s shirt and

to wait in the lobby. The CHS sent a photo of the shirt being worn by the CHS.

Shortly after, ALEX forwarded a message with a photo of a Gray “GAP” sweater

with a seatbelt strap across it. ALEX said the person was in the lobby. The CHS met

with the man, later identified as AGUASVIVAS, who wore the same Gray “GAP”

sweater as the photo previously provided by ALEX.

CHS told AGUASVIVAS that the CHS needed to take the money to the office

to verify the count. AGUASVIVAS did not want to let the money go without

receiving coins. AGUASVIVAS and associates always gave money and received

coins right away. The CHS advised AGUASVIVAS that the money needed to be

verified first before transferring the coins. AGUASVIVAS called someone he referred

to as his boss, who the FBI later identified. The CHS, AGUASVIVAS, and his boss,

agreed to receive all the coins while AGUASVIVAS remained in the lobby area and

waited for the money count to be verified during this transaction of approximately

$60,350.

There was an issue with the type of wallet provided by AGUASVIVAS and

his boss. AGUASVIVAS video called his boss again and eventually it got sorted out.
17
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 18 of 24 PageID 81

The CHS then proceeded to transfer the coins and took possession of a shopping bag

being held by AGUASVIVAS and walked to a staging location within the building.

The CHS subsequently returned to lobby area and notified AGUASVIVAS that the

money count was correct.

AGUASVIVAS had an additional approximately $150,000 to purchase coins.

The CHS advised AGUASVIVAS that since this quantity was larger, they would

have to do a different payment arrangement. AGUASVIVAS video called his boss

again and his boss agreed to receive 60% of the coins while AGUASVIVAS

remained in the lobby area and waited for the money count to be verified, then the

remaining 40% would be transferred. The CHS took possession of a luggage being

held by AGUASVIVAS and walked to staging location within the building. The

CHS subsequently returned to lobby area and notified AGUASVIVAS that the

money count was correct, and proceeded to transfer the coins. Once AGUASVIVAS

received the cryptocurrency, he departed and left the area in his vehicle, a black

BMW (KVFF22 FL). The count was confirmed to be $210,860, and the cash was

taken to the FBI Miami Field Office. In response to the cash provided by

AGUASVIVAS, an FBI CHS sent the corresponding USDT.

18
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 19 of 24 PageID 82

• December 2, 2021 – AGUASVIVAS Showed CHS Image of Cocaine

On December 2, 2021, the CHS previously contacted AGUASVIVAS via

Whatsapp messages using telephone number 786-972-7875 and set up a meeting. The

CHS met with AGUASVIVAS at La Carreta Restaurant located in Miami, Florida.

During the meeting, the CHS and AGUASVIVAS discussed cash to cryptocurrency

money deals and narcotics. AGUASVIVAS offered to provide a sample of cocaine to

the CHS in the future. AGUASVIVAS explained that he had the ability to move

approximately 50 kilograms of cocaine a week in Miami. AGUASVIVAS showed a

photo on his cellphone to the CHS of some of the cocaine he handles. The photo

showed a brick shaped, white powdery substance with the letter H imprinted on it,

which is depicted below:

19
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 20 of 24 PageID 83

• December 6, 2021 - Money Drop by AGUASVIVAS for $228,340

On December 6, 2021, AGUASVIVAS provided FBI CHS with

approximately $228,340, at the Intercontinental Hotel lobby located in Miami,

Florida. The cash was to be utilized to purchase USDT at a 2.5% fee. The

surveillance was conducted by FBI agents.

20
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 21 of 24 PageID 84

• December 14, 2021 – Money Drop by AGUASVIVAS for $98,940

On December 14, 2024, AGUASVIVAS met a CHS at the Intercontinental

Hotel in Miami, Florida, and provided the CHS with approximately $99,000 in cash

from a backpack that he carried into the lobby. The USDT was then sent to the

wallet ID that AGUASVIVAS had provided several hours earlier, after the count

was verified by agents. During the meeting, the CHS met with AGUASVIVAS’s

boss via a Facetime video call, and the boss agreed to allow AGUASVIVAS to drop

the money and receive the cryptocurrency several hours later after the count was

verified.

AGUASVIVAS discussed providing a kilo of cocaine to the CHS and the

quality of that cocaine. AGUASVIVAS said they had fifty kilograms and sold it all.

AGUASVIVAS says he will tell his boss about the proposition of working from

Colombia to Miami directly via private plane.

21
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 22 of 24 PageID 85

• December 15, 2021 – Money Drop by AGUASVIVAS for $100,000

On December 15, 2021, CHS conducted a $100,000 cryptocurrency deal with

AGUASVIVAS. During the deal, AGUASVIVAS provided his boss's phone number

to the CHS. AGUASVIVAS agreed to leave the cash with CHS’s and receive the

coins later. AGUASVIVAS had more cash at home and was driving to Orlando later

to stay overnight. All parties agreed that starting with this deal and moving forward,

there would only be one coin transfer from CHS’s to AGUASVIVAS; there would

not be a separate transfer with commission fee to ALEX.

During the deal, AGUASVIVAS provided the CHS’s phone number to his

boss. After the deal, the boss called the CHS and asked the CHS if he had an account

that could receive a wire transfer from the Central Bank of Venezuela and provided

the CHS with a picture of a wire transfer that did not go through. The picture shows

that the value of the transfer was 1000000900 Euros. He asked the CHS if he could

start with a transaction worth a couple of million dollars. The CHS communicated

with AGUASVIVAS via Whatsapp messages. CHS asked AGUASVIVAS about the

pending request (AGUASVIVAS previously agreed to sell CHS 1 Kilogram of

Cocaine); AGUASVIVAS said he was waiting for the man to return from

Dominican Republic.

22
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 23 of 24 PageID 86

The above is merely a summary of some of the events, some of the persons

involved, and other information relating to this case. It does not include, nor is it

intended to include, all the events, persons involved, or other information relating to

this case.

Respectfully submitted,

GREGORY W. KEHOE
United States Attorney

By: /s/ Michael P. Felicetta

MICHAEL P. FELICETTA
Assistant United States Attorney
Florida Bar No. 094468
400 W. Washington Street, Suite 3100
Orlando, Florida 32801
Telephone: (407) 648-7500
E-mail: [email protected]

23
Case 6:24-cr-00253-RBD-RMN Document 28 Filed 04/07/25 Page 24 of 24 PageID 87

U.S. v. AGUASVIVAS LIZARDO Case No. 6:24-cr-253-RBD-RMN

CERTIFICATE OF SERVICE

I hereby certify that on April 7, 2025, I electronically filed the foregoing with

the Clerk of the Court by using the CM/ECF system, which will send a notice of

electronic filing to the following:

Brett Meltzer, Esq.

/s/ Michael P. Felicetta

MICHAEL P. FELICETTA
Assistant United States Attorney
Florida Bar No. 094468
400 W. Washington Street, Suite 3100
Orlando, Florida 32801
Telephone: (407) 648-7500
E-mail: [email protected]

24