United States v. Erick Jason Victoria-Brito; Rene Victoria Rodriguez; Ashly Camacho Soto; Paul Antonio Liz; Luis Furniel Vasquez; and Abel Rodriguez Toribio, Southern District of New York (Jan. 29, 2025)

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 

UNITED STATES OF AMERICA 

- V . -

ERICK JASON VICTORIA- BRITO , 
RENE VICTORIA RODRIGUEZ , 
ASHLY CAMACHO SOTO , 
PAUL ANTONIO LIZ , 
LUIS FURNIEL VASQUEZ , and 
ABEL RODRIGUEZ TORIBIO , 

Defendants . 

X 

SEALED INDICTMENT 

22 Cr . 

..., 

~2 

X 

COUNT ONE 
(Conspiracy to Commit Bank Fraud) 

The Grand Jury charges : 

1 . From in or about December 2017 up to and including in or 

about November 2022 , in the Southern District of New York and 

elsewhere , ERICK JASON VICTORIA- BRITO , RENE VICTORIA RODRIGUEZ , 

ASHLY CAMACHO SOTO , PAUL ANTONIO LIZ , LUIS FURNIEL VASQUEZ , and 

ABEL RODRIGUEZ TORIBIO , the defendants , and others known and 

unknown , willfully and knowingly did combine , conspire , 

confederate , and agree , together and with each other , to commit 

bank fraud , in violation of Title 18 , United States Code , 

Section 1344 . 

2 . It was a part and object of the conspiracy that ERICK 

JASON VICTORIA-BRITO , RENE VICTORIA RODRIGUEZ , ASHLY CAMACHO SOTO , 

PAUL ANTONIO LIZ , LUIS FURNIEL VASQUEZ , and ABEL RODRIGUEZ TORIBIO , 



the defendants , and others known and unknown , would and did 

knowingly execute and attempt to execute a scheme and artifice to 

defraud financial institutions , the deposits of which were then 

insured by the Federal Deposit Insurance Corporation , and to obtain 

moneys , funds , credits , assets , securities , and other property 

owned by , and under the custody and control of , such financial 

institutions , by means of false and fraudulent pretenses , 

representations , and promises , in violation of Title 18 , United 

States Code , Section 134 4 , to wit , the defendants and others 

provided false and fraudulent information to financial 

institutions to open bank accounts that they used to obtain and 

transfer the proceeds of fraudulent schemes , including business e-

mail compromise schemes. 

(Title 18 , United States Code , Section 1349 . ) 

COUNT TWO 
{Conspiracy to Commit Money Laundering) 

The Grand Jury further charges : 

3 . From in or about December 2017 up to and including in or 

about November 2022 , in the Southern District of New York and 

elsewhere , ERICK JASON VICTORIA- BRITO , RENE VICTORIA RODRIGUEZ , 

ASHLY CAMACHO SOTO , PAUL ANTONIO LIZ , LUIS FURNIEL VASQUEZ , and 

ABEL RODRIGUEZ TORIBIO , the defendants , and others known and 

unknown , intentionally and knowingly did combine , conspire , 

confederate , and agree , together and with each other , to violate 

2 



Title 18 , United States Code , Sections 1956(a) (1) (B) (i) and 

1957 (a) . 

4 . It was a part and object of the conspiracy that ERICK 

JASON VICTORIA-BRITO , RENE VICTORIA RODRIGUEZ , ASHLY CAMACHO SOTO , 

PAUL ANTONIO LIZ , LUIS FURNIEL VASQUEZ , and ABEL RODRIGUEZ TORIBIO , 

the defendants , and others known and unknown , in an offense 

involving and affecting interstate and foreign commerce, knowing 

that the property involved in certain financial transactions , to 

wit , bank deposits, transfers , and withdrawals , represented the 

proceeds of some form of unlawful activity , would and did conduct 

and attempt to conduct such financial transactions , which in fact 

involved the proceeds of specified unlawful activity , to wit , the 

scheme to commit bank fraud described as the object of Count One 

of this Indictment , knowing that the transactions were designed in 

whole and in part to conceal and disguise the nature , the location , 

the source , the ownership , and the control of the proceeds of the 

specified unlawful activity , in violation of Title 18 , United 

States Code , Section 1956(a) (1) (B) (i) . 

5 . It was a further part and object of the conspiracy that 

ERICK JASON VICTORIA-BRITO , RENE VICTORIA RODRIGUEZ , ASHLY CAMACHO 

SOTO , PAUL ANTONIO LIZ , LUIS FURNIEL VASQUEZ , and ABEL RODRIGUEZ 

TORIBIO , the defendants , and others known and unknown , within the 

United States , knowingly would and did engage and attempt ~o engage 

in monetary transactions in criminal ly derived property of a value 

3 



greater than $10 , 000 and that was derived from specified unlawful 

activity , to wit , the scheme to commit bank fraud described as the 

object of Count One of this Indictment , in violation of Title 18 , 

United States Code , Section 1957(a) . 

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

FORFEITURE ALLEGATIONS 

6 . As a result of committing t h e offense alleged in Count 

One of this Indictment , ERICK JASON VICTORIA- BRITO , RENE VICTORIA 

RODRIGUEZ , ASHLY CAMACHO SOTO , PAUL ANTONIO LIZ , LUIS FURNIEL 

VASQUEZ , and ABEL RODRIGUEZ TORIBIO , the defendants , shall forfeit 

to the United States , pursuant to Title 18 , United States Code , 

Section 982 (a) (2) (A) , any and all property constituting , or 

derived from , proceeds the defendants obtained directly or 

indirectly , as a result of the commission of said offense , 

including but not limited to a sum of money in United States 

currency representing the amount of proceeds traceable to the 

commission of said offense . 

7 . As a result of committing the offense alleged in Count 

.Two of this Indictment , ERICK JASON VICTORIA- BRITO , RENE VICTORIA 

RODRIGUEZ , ASHLY CAMACHO SOTO , PAUL ANTONIO LIZ , LUIS FURNIEL 

VASQUEZ , and ABEL RODRIGUEZ TORIBIO , the defendants , shall forfeit 

to the United States , pursuant to Title 18 , United States Code , 

Section 982 (a) (1) , any and all property , real and personal , 

involved in said offense , or any property traceable to such 

4 



property , including but not limited to a sum of money in United 

States currency representing the amount of property involved in 

said offense . 

Substitute Assets Provision 

8 . If any of the above - described forfeitable property , as 

a result of any act or omission of the defendants : 

a . cannot be located upon the exercise of due 

diligence ; 

b . has been transferred or sold to , or deposited 

with , a third person ; 

c . has been placed beyond the jurisdiction of the 

Court ; 

d . has been substantially diminished in value ; or 

e . has been commingled with other property which 

cannot be subdivided without difficulty ; 

it is the intent of the United States , pursuant to Title 21 , United 

States Code , Section 853(p) and Title 28 , United States Code , 

5 



Section 2461(c) , to seek forfeiture of any other property of the 

defendants up to the value of the above forfeitable property . 

(Title 18 , United States Code , Section 982 ; 
Title 21 , United States Code , Section 853 ; and 
Title 28 , United States Code , Section 2461.) 

M cU,n,- C)n=-ry 
EPERSON DAMIAN WILLIAMS 

United States Attorney 

6 



Form No . USA- 33s-274 (Ed . 9- 25 - 58) 

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 

UNITED STATES OF AMERICA 

v. 

ERICK JASON VICTORIA-BRITO, 
RENE VICTORIA RODRIGUEZ, 

ASHLY CAMACHO SOTO, 
PAUL ANTONIO LIZ, 

LUIS FURNIEL VASQUEZ, and 
ABEL RODRIGUEZ TORIBIO, 

Defendants. 

SEALED INDICTMENT 

22 Cr . 

(18 U. S . C. §§ 1349 and 1956(h) . ) 

DAMIAN WILLIAMS 
United States Attorney 

Foreperson 

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ti rr~tr ~~lS /&tvvL

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 

UNITED STATES OF AMERICA 

- V . -

ERICK JASON VICTORIA- BRITO , 
RENE VICTORIA RODRIGUEZ , 
ASHLY CAMACHO SOTO , 
PAUL ANTONIO LIZ , 
LUIS FURNIEL VASQUEZ , and 
ABEL RODRIGUEZ TORIBIO , 

Defendants . 

X 

SEALED INDICTMENT 

22 Cr . 

..., 

~2 

X 

COUNT ONE 
(Conspiracy to Commit Bank Fraud) 

The Grand Jury charges : 

1 . From in or about December 2017 up to and including in or 

about November 2022 , in the Southern District of New York and 

elsewhere , ERICK JASON VICTORIA- BRITO , RENE VICTORIA RODRIGUEZ , 

ASHLY CAMACHO SOTO , PAUL ANTONIO LIZ , LUIS FURNIEL VASQUEZ , and 

ABEL RODRIGUEZ TORIBIO , the defendants , and others known and 

unknown , willfully and knowingly did combine , conspire , 

confederate , and agree , together and with each other , to commit 

bank fraud , in violation of Title 18 , United States Code , 

Section 1344 . 

2 . It was a part and object of the conspiracy that ERICK 

JASON VICTORIA-BRITO , RENE VICTORIA RODRIGUEZ , ASHLY CAMACHO SOTO , 

PAUL ANTONIO LIZ , LUIS FURNIEL VASQUEZ , and ABEL RODRIGUEZ TORIBIO , 



the defendants , and others known and unknown , would and did 

knowingly execute and attempt to execute a scheme and artifice to 

defraud financial institutions , the deposits of which were then 

insured by the Federal Deposit Insurance Corporation , and to obtain 

moneys , funds , credits , assets , securities , and other property 

owned by , and under the custody and control of , such financial 

institutions , by means of false and fraudulent pretenses , 

representations , and promises , in violation of Title 18 , United 

States Code , Section 134 4 , to wit , the defendants and others 

provided false and fraudulent information to financial 

institutions to open bank accounts that they used to obtain and 

transfer the proceeds of fraudulent schemes , including business e-

mail compromise schemes. 

(Title 18 , United States Code , Section 1349 . ) 

COUNT TWO 
{Conspiracy to Commit Money Laundering) 

The Grand Jury further charges : 

3 . From in or about December 2017 up to and including in or 

about November 2022 , in the Southern District of New York and 

elsewhere , ERICK JASON VICTORIA- BRITO , RENE VICTORIA RODRIGUEZ , 

ASHLY CAMACHO SOTO , PAUL ANTONIO LIZ , LUIS FURNIEL VASQUEZ , and 

ABEL RODRIGUEZ TORIBIO , the defendants , and others known and 

unknown , intentionally and knowingly did combine , conspire , 

confederate , and agree , together and with each other , to violate 

2 



Title 18 , United States Code , Sections 1956(a) (1) (B) (i) and 

1957 (a) . 

4 . It was a part and object of the conspiracy that ERICK 

JASON VICTORIA-BRITO , RENE VICTORIA RODRIGUEZ , ASHLY CAMACHO SOTO , 

PAUL ANTONIO LIZ , LUIS FURNIEL VASQUEZ , and ABEL RODRIGUEZ TORIBIO , 

the defendants , and others known and unknown , in an offense 

involving and affecting interstate and foreign commerce, knowing 

that the property involved in certain financial transactions , to 

wit , bank deposits, transfers , and withdrawals , represented the 

proceeds of some form of unlawful activity , would and did conduct 

and attempt to conduct such financial transactions , which in fact 

involved the proceeds of specified unlawful activity , to wit , the 

scheme to commit bank fraud described as the object of Count One 

of this Indictment , knowing that the transactions were designed in 

whole and in part to conceal and disguise the nature , the location , 

the source , the ownership , and the control of the proceeds of the 

specified unlawful activity , in violation of Title 18 , United 

States Code , Section 1956(a) (1) (B) (i) . 

5 . It was a further part and object of the conspiracy that 

ERICK JASON VICTORIA-BRITO , RENE VICTORIA RODRIGUEZ , ASHLY CAMACHO 

SOTO , PAUL ANTONIO LIZ , LUIS FURNIEL VASQUEZ , and ABEL RODRIGUEZ 

TORIBIO , the defendants , and others known and unknown , within the 

United States , knowingly would and did engage and attempt ~o engage 

in monetary transactions in criminal ly derived property of a value 

3 



greater than $10 , 000 and that was derived from specified unlawful 

activity , to wit , the scheme to commit bank fraud described as the 

object of Count One of this Indictment , in violation of Title 18 , 

United States Code , Section 1957(a) . 

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

FORFEITURE ALLEGATIONS 

6 . As a result of committing t h e offense alleged in Count 

One of this Indictment , ERICK JASON VICTORIA- BRITO , RENE VICTORIA 

RODRIGUEZ , ASHLY CAMACHO SOTO , PAUL ANTONIO LIZ , LUIS FURNIEL 

VASQUEZ , and ABEL RODRIGUEZ TORIBIO , the defendants , shall forfeit 

to the United States , pursuant to Title 18 , United States Code , 

Section 982 (a) (2) (A) , any and all property constituting , or 

derived from , proceeds the defendants obtained directly or 

indirectly , as a result of the commission of said offense , 

including but not limited to a sum of money in United States 

currency representing the amount of proceeds traceable to the 

commission of said offense . 

7 . As a result of committing the offense alleged in Count 

.Two of this Indictment , ERICK JASON VICTORIA- BRITO , RENE VICTORIA 

RODRIGUEZ , ASHLY CAMACHO SOTO , PAUL ANTONIO LIZ , LUIS FURNIEL 

VASQUEZ , and ABEL RODRIGUEZ TORIBIO , the defendants , shall forfeit 

to the United States , pursuant to Title 18 , United States Code , 

Section 982 (a) (1) , any and all property , real and personal , 

involved in said offense , or any property traceable to such 

4 



property , including but not limited to a sum of money in United 

States currency representing the amount of property involved in 

said offense . 

Substitute Assets Provision 

8 . If any of the above - described forfeitable property , as 

a result of any act or omission of the defendants : 

a . cannot be located upon the exercise of due 

diligence ; 

b . has been transferred or sold to , or deposited 

with , a third person ; 

c . has been placed beyond the jurisdiction of the 

Court ; 

d . has been substantially diminished in value ; or 

e . has been commingled with other property which 

cannot be subdivided without difficulty ; 

it is the intent of the United States , pursuant to Title 21 , United 

States Code , Section 853(p) and Title 28 , United States Code , 

5 



Section 2461(c) , to seek forfeiture of any other property of the 

defendants up to the value of the above forfeitable property . 

(Title 18 , United States Code , Section 982 ; 
Title 21 , United States Code , Section 853 ; and 
Title 28 , United States Code , Section 2461.) 

M cU,n,- C)n=-ry 
EPERSON DAMIAN WILLIAMS 

United States Attorney 

6 



Form No . USA- 33s-274 (Ed . 9- 25 - 58) 

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 

UNITED STATES OF AMERICA 

v. 

ERICK JASON VICTORIA-BRITO, 
RENE VICTORIA RODRIGUEZ, 

ASHLY CAMACHO SOTO, 
PAUL ANTONIO LIZ, 

LUIS FURNIEL VASQUEZ, and 
ABEL RODRIGUEZ TORIBIO, 

Defendants. 

SEALED INDICTMENT 

22 Cr . 

(18 U. S . C. §§ 1349 and 1956(h) . ) 

DAMIAN WILLIAMS 
United States Attorney 

Foreperson 

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ti rr~tr ~~lS /&tvvL