United States v. CHARL IE HERNADEZ; and SARAH VALERIO PUJOLS, Southern District of New York (May 8, 2024) — Complaint

AUSAs: Benjamin A. Gianforti, Jackie Delligatti 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
UNITED STATES OF AMERICA 
v. 
CHARL
IE HERNADEZ and 
SARAH VALERIO PUJOLS, 
Defendants. 
      SEALED COMPLAINT 
Viol
ations of 18 U.S.C. §§ 1960, 2, and 
371, 31 U.S.C. § 5332, 49 U.S.C. §§ 
46314(a) and (b)(2). 
      COUNTY OF OFFENSE: 
      BRONX 
SOUTHE
RN DISTRICT OF NEW YORK, ss.: 
CHRI
STOPHER  FANT,  being  duly  sworn,  deposes  and  says  that  he  is  a  Special  Agent 
with the Homeland Security Investigations (“HSI”), and charges as follows: 
COUNT ONE 
(Operation of an Unlicensed Money Transmission Business) 
1.From
 at least in or about 2014 through at least in or about 2019, in the Southern
District  of  New  York  and  elsewhere,  CHARLIE  HERNANDEZ,  the  defendant,  knowingly 
conducted,  controlled,  managed,  supervised,  directed,  and  owned  all  and  part  of  an  unlicensed  
money transmitting business, which affected interstate and foreign commerce and (i) was operated 
without an appropriate money transmitting license in a State where such operation was punishable 
as a misdemeanor or a felony under State law; (ii) failed to comply with the money transmitting 
business  registration  requirements  under  Section  5330  of  Title  31,  United  States  Code,  and  
regulations  prescribed  under  such  section;  and  (iii)  otherwise  involved  the  transportation  and  
transmission  of  funds  that  were  known  to  the  defendant  to  have  been  derived  from  a  criminal  
offense  and  to  be  intended  to  be  used  to  promote  and  support  unlawful  activity,  to  wit,  
HERNANDEZ conducted, controlled, managed, supervised, directed, and owned all or part of an 
unlicensed  money  transmission  business  that  transferred  funds  on  behalf  of  the  public,  without 
meeting the Federal or State registration requirements set forth for money transmitting businesses 
by smuggling bulk currency from New York City to the Dominican Republic in exchange for a 
fee that he knew was derived from a criminal offense and was intended to be used to promote and 
support unlawful activity. 
(Ti
tle 18, United States Code, Sections 1960 & 2.) 
COUNT TWO 
(Operation of an Unlicensed Money Transmission Business) 
2.From at least in or about 2014 through at least in or about 2019, in the Southern
District  of  New  York  and  elsewhere,  SARAH  VALERIO  PUJOLS,  the  defendant,  knowingly 
conducted,  controlled,  managed,  supervised,  directed,  and  owned  all  and  part  of  an  unlicensed  
money transmitting business, which affected interstate and foreign commerce and (i) was operated 
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without an appropriate money transmitting license in a State where such operation was punishable 
as a misdemeanor or a felony under State law; (ii) failed to comply with the money transmitting 
business  registration  requirements  under  Section  5330  of  Title  31,  United  States  Code,  and  
regulations  prescribed  under  such  section;  and  (iii)  otherwise  involved  the  transportation  and  
transmission  of  funds  that  were  known  to  the  defendant  to  have  been  derived  from  a  criminal  
offense and to be intended to be used to promote and support unlawful activity, to wit, PUJOLS 
conducted,  controlled,  managed,  supervised,  directed,  and  owned  all  or  part  of  an  unlicensed  
money transmission business that transferred funds on behalf of the public, without meeting the 
Federal  or  State  registration  requirements  set  forth  for  money  transmitting  businesses  by  
smuggling bulk currency from New York City to the Dominican Republic in exchange for a fee 
that she knew was derived from a criminal offense and was intended to be used to promote and 
support unlawful activity. 
(Title 18, United States Code, Sections 1960 & 2.) 
COUNT THREE 
(Conspiracy to Operate an Unlicensed Money Transmitting Business) 
3.Fro
m  at least in or about 2014 through at least in or about 2019, in the Southern
District  of  New  York  and  elsewhere,  CHARLIE  HERNANDEZ  and  SARAH  VALERIO  
PUJOLS, the defendants, and others known and unknown, willfully and knowingly did combine, 
conspire,  confederate,  and  agree  together  and  with  each  other  to  commit  an  offense  against  the  
United States, to wit, operation of an unlicensed money transmitting service, in violation of Title 
18, United State Code, Section 1960. 
4.It  was  a  part  and  an  object  of  the  conspiracy  that  CHARLIE  HERNANDEZ  and
SARAH VALERIO PUJOLS, the defendants, and others known and unknown, knowingly would 
and did conduct, control, manage, supervise, direct, and own all and part of an unlicensed money 
transmitting  business  affecting  interstate  and  foreign  commerce,  which  (i)  operated  without  an  
appropriate  money  transmitting  license  in  New  York,  where  such  operation  is  punishable  as  a  
misdemeanor or felony under State law; (ii) failed to comply with the money transmitting  business 
registration  requirements  set  forth  in  Title  31,  United  States  Code,  Section  5330,  and  the  
regulations prescribed thereunder; and (iii) otherwise involved the transportation and transmission 
of funds that were known to the defendants   to have been derived from a criminal offense and to 
be intended to be used to promote and support unlawful activity.  
Overt Acts 
5.In furtherance of the conspiracy, and to effect the illegal objects thereof, CHARLIE
HERNANDEZ and SARAH VALERIO PUJOLS, the defendants, committed the following overt 
acts, in the Southern District of New York and elsewhere: 
a.On  or  about  December  20,  2019,  a  cooperating  witness  (“CW-1”)  met  with
HERNANDEZ   in   the   Bronx.   During   the   meeting,   CW-1   provided   HERNANDEZ   with   
approximately   $121,215   in   proceeds   derived   from   narcotics   trafficking.   The   same   day, 

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HERNANDEZ gave approximately $61,215 to PUJOLS for the purpose of transporting it to the 
Dominican Republic and kept $60,000 to transport to the Dominican Republic himself.  
(Title 18, United States Code, Section 371) 
COUNT FOUR 
(Bulk Cash Smuggling) 
 
6. In or about December 2019, in the Southern District of New York and elsewhere, 
SARAH  VALERIO  PUJOLS,  the  defendant,  with  the  intent  to  evade  a  currency  reporting  
requirement  under  31  U.S.C.  §  5316,  knowingly  concealed  more  than  $10,000  in  currency  and  
other monetary instruments on her person and in any conveyance, article of luggage, merchandise, 
and other container, and transported and transferred and attempted to transport and transfer such 
currency and monetary instruments from a place within the United States to a place outside of the 
United States, and from a place outside the United States to a place within the United States. 
 
(Title 31, United States Code, Sections 5332 & 2.) 
 
COUNT FIVE 
(Entering an Airport or Aircraft Area in Violation of Security Requirements) 
 
7. From at least in or about 2014 through at least in or about 2019, in the Southern 
District of New York and elsewhere, CHARLIE HERNANDEZ, the defendant, did knowingly and 
willfully  enter  an  aircraft  or  an  airport  area  that  serviced  an  air  carrier  or  foreign  air  carrier,  in  
violation of security requirements proscribed under Title 49, United States Code, Section 44901, 
44903(b) and (c), with the intent to evade security procedures and restrictions and with the intent 
to commit, in the aircraft and airport area, a felony under the law of the United States and a State, 
namely, operation of an unlicensed money transmission business, in violation of Title 18, United 
States  Code,  Section  1960, to  wit,  HERNANDEZ  entered  the  secure  passenger  area  at  John  F.  
Kennedy International Airport (“JFK”) with the intent to evade security procedures and restrictions 
in order to smuggle bulk currency he knew was derived from a criminal offense with the intent to 
operate an unlicensed money transmission business, in violation of 18 U.S.C. § 1960. 
 
(Title 49, United States Code, Sections 46314(a) and (b)(2).) 
 
COUNT SIX 
(Entering an Airport or Aircraft Area in Violation of Security Requirements) 
 
8. From at least in or about 2014 through at least in or about 2019, in the Southern 
District of New York and elsewhere, SARAH VALERIO PUJOLS, the defendant, did knowingly 
and willfully enter an aircraft or an airport area that serviced an air carrier or foreign air carrier, in 
violation of security requirements proscribed under Title 49, United States Code, Section 44901, 
44903(b) and (c), with the intent to evade security procedures and restrictions and with the intent 
to commit, in the aircraft and airport area, a felony under the law of the United States and a State, 
namely, operation of an unlicensed money transmission business, in violation of Title 18, United 
States Code, Section 1960, to wit, PUJOLS entered the secure passenger area at JFK with the intent 
to  evade  security  procedures  and  restrictions  in  order  to  smuggle  bulk  currency  she knew  was  

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derived  from  a  criminal  offense  with  the  intent  to  operate  an  unlicensed  money  transmission  
business, in violation of 18 U.S.C. § 1960. 
 
(Title 49, United States Code, Sections 46314(a) and (b)(2).) 
 
The bases for my knowledge and for the foregoing charges are, in part, as follows: 
9. I have been a Special Agent with HSI for approximately six years. During that time, 
I  have  participated  in  numerous  investigations  of  unlawful  narcotics  distribution  and  associated  
money laundering, as well as bulk cash smuggling in violation of Title 31, United States Code, 
Section  5332.  During  the  course  of  those  investigations,  I  have  conducted  or  participated  in  
surveillance,   narcotics   and   money   transactions   with   undercover   officers   and   confidential   
witnesses,  the  execution  of  search  warrants,  debriefings  of  witnesses,  and  reviews  of  taped  
conversations and other records relating to narcotics transactions. Through my training, education, 
and experience, I have become familiar with the manner in which illegal narcotics are imported 
and distributed; the way in which illegal narcotics are prepared, packaged, and sold on the street; 
some  of  the  methods  of  payment  for  such  narcotics;  and  some  of  the  methods  that  are  used  to  
disguise the source and nature of the profits made by narcotics dealers. 
10. I make this Affidavit in part on personal knowledge based on my participation in 
the investigation and conversations with other HSI Special Agents and Task Force Officers, and 
other law enforcement officers; conversations with two cooperating witnesses (CW-1 and “CW-
2”)
1
;  reviews  of  reports  and  other  documents  prepared  by  agents  and  others;  and  physical  
surveillance. 
11. Throughout this Affidavit, where I assert that a statement was made, I was not the 
individual  to  whom  the  statement  was  made  unless  I  specifically  so  state.  Rather,  information  
about the statement was provided by the specified law-enforcement officer or another individual 
to whom I have spoken or whose reports I have read and reviewed. In addition, unless otherwise 
noted,  the  conversations  from  which  the  statements  referenced  herein  were  sourced  were  
conducted principally in Spanish and later translated into English. All statements referenced herein 
 
1
 CW-1 has been cooperating with law enforcement since CW-1’s arrest in or about October 2021 
on  money  laundering,  bulk  cash  smuggling,  and  narcotics  distribution  charges,  in  the  hopes  of  
ultimately receiving leniency when CW-1 is sentenced for CW-1’s crimes.  The information CW-
1  has  provided  to  law  enforcement  has  proven  credible  and  has  been  corroborated  by  other  
evidence, including, among other things, CW-1 and CW-2’s communications with the defendants 
and recordings CW-1 and CW-2 have made of meetings with the defendants.  
 
CW-2  has  been  cooperating  with  law  enforcement  since  being  charged  with  money  laundering,  
bulk  cash  smuggling,  and  narcotics  distribution  charges  along  with  CW-1  in  or  about  October  
2021. Because CW-2 resides in the Dominican Republic, and was there at the time CW-1 and CW-
2 were charged, CW-2 has not been arrested on these charges. Nonetheless, CW-2 is cooperating 
with law enforcement in the hopes of receiving leniency when CW-2 is ultimately sentenced for 
CW-2’s crimes. The information CW-2 has provided to law enforcement has proven credible and 
has  been  corroborated  by  other  evidence,  including,  among  other  things,  CW-1  and  CW-2’s 
communications with the defendants and recordings CW-1 and CW-2 have made of meetings with 
the defendants. 

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are among many statements made by others and they are set forth in substance and in part, unless 
otherwise indicated. Similarly, the information in this Affidavit resulting from surveillance, except 
where otherwise specifically indicated, does not set forth my personal observations, but rather was 
provided to me by other law-enforcement officers who observed the events described, and/or to 
whom I have spoken or whose reports I have read. 
12. Furthermore,   the   facts   and   circumstances   of   this   investigation   have   been   
summarized  for  the  specific  purposes  of  this  Application.  I  have  not  attempted  to  set  forth  the  
complete factual history of this investigation or all of its details. In making this Application, I rely 
only on the facts stated herein. 
 
Background to the Investigation 
13. Since  approximately  December  2018,  HSI  and  the  New  York  City  Police  
Department (“NYPD”) have been investigating an international narcotics trafficking and money 
laundering organization involved in, among other things, trafficking fentanyl in the United States 
and  moving  the  proceeds  of  narcotics  trafficking  from  the  United  States  to  the  Dominican  
Republic, including by using flight attendants at major airlines to smuggle bulk quantities of cash.  
Law  enforcement  officers  have  been  conducting  this  investigation  with  the  assistance  of  CW-1 
and CW-2.  CW-1 was a member of this money laundering organization and has used a number of 
different flight attendants to smuggle bulk cash to the Dominican Republic, including CHARLIE 
HERNANDEZ and SARAH VALERIO PJUOLS, the defendants. CW-2 was also a member of 
this money laundering organization and has assisted CW-1 with the transport of bulk cash from 
the United States to the Dominican Republic. 
Background on the Known Crewmember (KCM) Program 
14. From my training and experience, including my participation in this investigation 
and my discussions with other law enforcement officers, I have learned, among other things, that 
international  narcotics  traffickers  who  traffick  narcotics  in  the  United  States  often  accumulate  
significant cash proceeds that need to be moved outside of the United States. In particular, I have 
learned that narcotics traffickers who operate from the Dominican Republic often prefer to receive 
the proceeds from their illegal activity in the United States in cash, rather than relying on banking 
services.  This  requires  the  smuggling  of  large  quantities  of  cash  from  the  United  States  to  the  
Dominican Republic. One common tactic for smuggling cash to the Dominican Republic involves 
paying flight attendants who work routes between U.S. cities and the Dominican Republic to move 
large quantities of cash.  I have learned the following about this scheme: 
a. Flight  attendants  are  ideal  for  smuggling  bulk  cash  because  they  generally  have  
“Known   Crewmember”   (“KCM”)   status   with   the   Transportation   Security   Administration   
(“TSA”),  which  allows  airline  employees  to  pass  through  airport  security  more  quickly  via  a  
dedicated KCM lane that typically entails less scrutiny. JFK, from which all the flights relevant to 
this complaint were taken, has a KCM lane. 
b. Unlike the security screening process for ordinary passengers, which requires that 
passengers place their belongings through an x-ray machine, the KCM lane does not automatically 
require airline employees to place their belongings through an x-ray machine. Once an individual 
goes  through  security—whether  the  ordinary  security  screen  process  or  the  KCM  lane—that 

6 
individual enters the “sterile,” area, from which it is possible to access airplanes and other secure 
areas of the airport. 
c.KCM privileges are available to airline employees such as flight attendants whose
airline participates in the KCM program. Airline employees must present valid identification each 
time  they  wish  to  use  the  KCM  lane.  Individuals  with  KCM  privileges  are  permitted  to  bring  
personal property through the KCM lane so long as the property is not on TSA’s prohibited items 
list.  This  applies  to  personal  property.  Those  with  KCM  privileges  may  not  bring  property  
belonging to other individuals through the KCM lane. 
d.   Individuals who gain KCM privileges through their employing airline may use the
KCM lane only for (1) business travel related to their employing airline, and (2) domestic personal 
travel. Such individuals are not required to wear their crewmember uniform to use the KCM lane. 
However, those who are in uniform receive certain privileges not afforded to those who are not in 
uniform.  
e.If  an  airline  employee  attempts  to  use  the  KCM  lane  and  the  TSA  employee
monitoring the KCM lane has any concerns about that employee’s security status, he or she may 
take follow-up steps, including referring the airline employee to the ordinary screening process. 
f.In  effect,  given  these  loosened  security  procedures,  KCM  privileges  allow  flight
attendants to bypass airport security with large quantities of cash without that cash being seized.  
Background on the Registration of Money Transmitting Businesses 
15.From my training and experience, including my participation in this investigation
and my discussions with other law enforcement officers, I have learned, among other things, the 
following: 
a.New  York  law  requires  anyone  operating  a  money  transmitting  business  to  be
licensed. In particular New York State Banking Law Section 641(1) provides in pertinent part that 
“[n]o  person  shall...engage  in  the  business  of  receiving  money  for  transmission  or  transmitting  
the same, without a license therefor obtained from the superintendent as provided in this article, 
nor shall any person engage in such business as an agent, except as an agent of a licensee or as 
agent of a payee.” 
b.Under federal law, money transmitting businesses must also be registered with the
U.S.  Department  of  Treasury.  For  instance,  Title  31,  United  States  Code,  Section  5330(a)(1)  
provides  that  “[a]ny  person  who  owns  or  controls  a  money  transmitting  business  shall  register  
(whether or not the business is licensed as a money transmitting business in any State) with the 
Secretary of the Treasury.” Section 5330(d)(1), in turn, explains, in part, that the “term ‘money 
transmitting business’ means...(A) any...person who engages as a business in the transmission of 
currency, funds, or  value  that  substitutes  for  currency,  including  any  person  who  engages  as  a  
business in an informal money transfer system or any network of people who engage as a business 
in  facilitating  the  transfer  of  money  domestically  or  internationally  outside  of  the  conventional  

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financial  institutions  system;  (B)  is  required  to  file  reports  under  section  5313;  and  (C)  is  not  a  
depository institution (as defined in section 5313(g).”
2
 
c. The New York and federal requirements for money transmitting businesses apply 
to formal and informal arrangements alike. 
16. Based  on  my  review  of records  from  New  York  State  and  FinCEN,  I  know  that  
neither CHARLIE HERNANDEZ, nor SARAH VALERIO PUJOLS, has ever held a New York 
State or federal money transmission license. 
HERNANDEZ and PUJOLS’s Participation in the Smuggling of Narcotics Proceeds 
17. Based on my discussions with other law enforcement officers participating in this 
investigation and CW-1, and my review of reports drafted by other members of law enforcement, 
recordings, and other records, I have learned, among other things, the following: 
 
b. CHARLIE HERNANDEZ, the defendant, has worked as a flight attendant since at 
least in or about 2007, including for a certain international airline (the “International Airline”). In 
or  about  2014  or  2015,  CW-1  began  using  HERNANDEZ  to  smuggle  narcotics  proceeds  from  
New York City to the Dominican Republic. CW-1 estimates that HERNANDEZ smuggled at least 
approximately $2,500,000 in narcotics proceeds from the United States to the Dominican Republic 
at  CW-1’s  direction  between  in  or  about  2014 and  in  or  about  2019 in  exchange  for  a  fee—
generally, a low percentage of the amount of cash HERNANDEZ smuggled on CW-1’s behalf. 
Over  the  course  of  their  relationship,  CW-1  told  HERNANDEZ  on  multiple  occasions  that  the  
cash  HERNANDEZ  was  smuggling  to  the  Dominican  Republic  was  derived  from  narcotics 
trafficking. On at least one occasion, CW-1 and HERNANDEZ attended a party in the Dominican 
Republic where CW-1 introduced HERNANDEZ to a narcotics dealer who was one of CW-1’s 
money laundering clients.  
 
2
 The Secretary of the Treasury has the authority to establish which individuals and entities are 
subject to 31 U.S.C. 5330’s registration requirement. 31 U.S.C. §§ 5313(a); 5330(a)(2) & (c)(1). 
These  regulations  are  contained  in  the  Code  of  Federal  Regulations  (“CFR”).  In  particular,  31  
C.F.R. § 1022.380(a)(1) provides that “each money services business (whether or not licensed as 
a money services business by any State) must register with FinCEN ...as required by 31 U.S.C. 
5330[.]” 31 C.F.R. § 1010.100(ff) includes a “money transmitter”   as a “money services business.” 
The  term  “money  transmitter”    is,  in  turn,  defined  to  include “a  person  that  provides  money  
transmission services.”  The term “money transmission services” is defined as “the acceptance of 
currency, funds, or other value that substitutes for currency from one person and the transmission 
of currency, funds, or other value that substitutes for currency to another location or person by any 
means.” Id. “Any means” is defined as including, but not limited to, “through a financial agency 
or institution; a Federal Reserve Bank or other facility of one or more Federal Reserve Banks, the 
Board of Governors of the Federal Reserve System, or both; an electronic funds transfer network; 
or  an  informal  value  transfer  system.” Id.    Moreover,  “money  transmitter”  is  defined  as  “[a]ny  
other person engaged in the transfer of funds.” Id.  Accordingly, the Treasury regulations establish 
that any person engaged in the transfer of funds is required to register with FinCEN. 
 

8 
c.SARAH VALERIO PUJOLS, the defendant, has worked as a flight attendant since
at least in or about 2009 or 2010, including for the International Airline. In or about 2014 or 2015, 
CW-1 began using PUJOLS to smuggle narcotics proceeds from New York City to the Dominican 
Republic, and PUJOLS continued to smuggle narcotics proceeds for CW-1 until as recently as in 
or  about  2019. CW-1  estimates  that  PUJOLS  smuggled  at  least  approximately  $1,500,000  in  
narcotics proceeds from the United States to the Dominican Republic at CW-1’s direction between 
in or about 2014 and in or about 2019 in exchange for a fee—generally, a low percentage of the 
amount of cash PUJOLS smuggled on CW-1’s behalf. PUJOLS was aware that the money was 
from narcotics trafficking because CW-1 would often refer to picking up money from “los tigres,” 
which, based on my training and experience, as well as my discussions with CW-1, I understand 
to be a Spanish slang term for narcotics dealers.  
d.HERNANDEZ and PUJOLS were aware that they both were smuggling narcotics
proceeds for CW-1. CW-1 would often refer to giving bulk currency to PUJOLS when CW-1 was 
with HERNANDEZ and vice versa.  
e.In or about December 2019, both HERNANDEZ and PUJOLS were employed as
flight attendants   with the International Airline. On or about December 20, 2019, CW-1 met with 
HERNANDEZ   in   the   Bronx.   During   the   meeting,   CW-1   provided   HERNANDEZ   with   
approximately   $121,215   in   proceeds   derived   from   narcotics   trafficking.   The   same   day, 
HERNANDEZ gave approximately $61,215 to PUJOLS for the purpose of transporting it to the 
Dominican Republic and kept $60,000 to transport to the Dominican Republic himself.  
f.Later  that  day,  before  boarding  an  International  Airline  flight  from  JFK to  the
Dominican  Republic,  PUJOLS  was  stopped  by  agents  with  Customs  and  Border  Protection  
(“CBP”).  The  CBP  agents  explained  to  PUJOLS  the  restrictions  on transporting  United  States  
currency  internationally  under  Title  31  of  the  United  States  Code  and  asked  her  to  report  any  
United  States  currency  she  intended  to  bring  out  of  the  country.  PUJOLS  orally  reported  her  
possession  of  approximately  $1,000  and  filled  out  a  CBP  form  making  the  same  affirmation.  
PUJOLS  also  produced  approximately  $1,215  from  her  wallet  for  the  CBP  agents’  inspection.  
Upon further inspection, however, the CBP agents found approximately $60,000 in United States 
currency in three bundles concealed in PUJOLS’s purse, which they seized. After PUJOLS was 
stopped  by  CBP,  HERNANDEZ  contacted  CW-1  to  tell  CW-1  about  the  stop  and  the  seizure.  
HERNANDEZ did not deliver the remaining approximately $60,000 that CW-1 gave him. CW-1 
does not know what HERNANDEZ did with the cash. 

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g.Following   the   incident   described   above,   PUJOLS   was   terminated   by   the
International Airline. 
WHEREFORE, I respectfully request that a warrant be issued for the arrest of CHARLIE 
HERNANDEZ and SARAH VALERIO PUJOLS, the defendants, and that they be arrested, and 
imprisoned or bailed, as the case may be. 
______________________________ 
Chri
stopher Fant 
Special Agent 
HSI 
Sworn to me t   hrough the transmission of  
this Complaint by reliable electronic  
means (
Telephone), this ___ day of April, 
2024. 
___________________________________ 
THE HONOR
ABLE SARAH L. CAVE 
United States Magistrate Judge 
Southern District of New York 
/s Christopher Fant  (By Court with Authorization)
30th