United States v. DAVID ELIGOOLA, Southern District of New York (Apr. 17, 2024) — Complaint

AUSAs: Micah Fergenson, Kevin Mead 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
UNITED STATES OF AMERICA 
v. 
DAVID ELIGOOLA, 
Defendant. 
      SEALED COMPLAINT 
      Violation of 18 U.S.C. § 1956(h) 
      COUNTY OF OFFENSE: 
      NEW YORK 
S
OUTHERN DISTRICT OF NEW YORK, ss.: 
LARISSA MONTES, being duly sworn, deposes and says that she is a Special Agent with 
the Federal Bureau of Investigation (“FBI”), and charges as follows: 
COUNT ONE 
(Money Laundering Conspiracy) 
1.From at least in or about June 2022 up to and including in or about July 2023, in
the Southern District of New York and elsewhere, DAVID ELIGOOLA, the defendant, and others 
known  and  unknown,  willfully  and  knowingly  combined,  conspired,  confederated,  and  agreed  
together and with each other to commit money laundering, in violation of Title 18, United States 
Code, Section 1956(a)(3)(B). 
2.It  was  a  part  and  an  object  of  the  conspiracy  that  DAVID  ELIGOOLA,  the
defendant,  and  others  known  and  unknown,  with  the  intent  to  conceal  and  disguise  the  nature,  
location,  source,  ownership,  and  control  of  property  believed  to  be  the  proceeds  of  specified  
unlawful activity, to wit, narcotics trafficking, in violation of Title 21, United States Code, Section 
841,  would  and  did  conduct  and  attempt  to  conduct  a  financial  transaction,  which  transaction  
affected interstate and foreign commerce and involved the use of a financial institution which was 
engaged  in,  and  the  activities  of  which  affected,  interstate  and  foreign  commerce,  involving  
property  represented  to  be  the  proceeds  of  specified  unlawful  activity,  to  wit,  the  proceeds  of  
narcotics trafficking, in violation of Title 21, United States Code, Section 841, in violation of Title 
18, United States Code, Section 1956(a)(3)(B). 
(T
itle 18, United States Code, Section 1956(h).) 
Summary 
3.The  father  (“CC-1”)  of  DAVID  ELIGOOLA,  the  defendant,  arranged  to  launder
money for an individual he understood to be working on behalf of drug cartels in South America, 
who was, in truth and in fact, an undercover agent with the FBI (“UC-1”).  Specifically, UC-1 gave 
CC-1 large amounts of cash, and CC-1 transferred the funds back to UC-1 via cryptocurrency and
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4 MAG 1492

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bank wires.  CC-1 specifically asked UC-1 if the money constituted drug proceeds, and UC-1 said 
yes.  CC-1 laundered over half a million dollars represented by UC-1 to be narcotics proceeds. 
 
4. That half a million dollars was transferred by undercover agents in cash over several 
transactions to,   variously, DAVID   ELIGOOLA,   the   defendant,   CC-1,   and   an   additional   
coconspirator.  ELIGOOLA personally received two cash handoffs—one of $60,000 on March 22, 
2023,  and  one  of  $116,000,  on  May  22,  2023.    In ELIGOOLA’s  conversations  with  those  
undercover agents, it was clear that he understood that the cash represented proceeds of narcotics 
trafficking that he was assisting in laundering. 
 
CC-1’s Initial Conversations with FBI Undercover Officers 
 
5. In or about June 2022, UC-1 began communicating with CC-1 by phone.
1
  UC-1 
and CC-1 discussed UC-1 transferring money to CC-1.   
 
6. On or about January 17, 2023, CC-1 and UC-1 met in person.  That meeting was 
consensually recorded.  Based on my review of the recording and my discussions with other law 
enforcement officers, I know that the following, in substance and in part, took place at the meeting:  
 
a. CC-1 discussed how he could receive any amount of cash and could transfer 
it back to UC-1 within five days. 
 
b. CC-1 said that if he received cash from UC-1 in New York and transferred 
it back to a New York bank account, he would charge a rate of 10 to 12 percent. 
 
c. CC-1 said that an individual working for him would pick up the cash from 
UC-1. 
 
d. CC-1 said that UC-1 should tell him what CC-1 should tell his bank about 
why he was wiring the money to UC-1. 
 
e. CC-1 asked if the cash that UC-1 planned to give him was “from drugs.”  
UC-1 said yes, that the money was from drugs, and that he was “dealing with Colombians.”  
 
f. CC-1 told  UC-1  he  would  charge  a  lower  fee  if  UC-1  would  accept  
cryptocurrency in exchange for his cash. 
 
g. CC-1 told UC-1 that they should use encrypted messaging applications to 
discuss their transactions. 
 
h. CC-1 told UC-1 that when UC-1 received the wires from CC-1, “the bank 
will never ask you a question.”   
 
7. On or about February 14, 2023, CC-1 and UC-1 met in person in New York, New 
York.  That meeting was consensually recorded.  Based on my review of the recording and my 
 
1
 The communications involving FBI undercover agents were recorded, and I know about those 
communications from reviewing the recordings and reports summarizing the recordings. 

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discussions  with  other  law  enforcement  officers,  I  know  that  the  following,  in  substance  and  in  
part, took place at the meeting: 
 
a. CC-1 told  UC-1  that  he  could  launder  up  to  $1 million in cash per day if 
CC-1 could transfer the money back to UC-1 in the form of cryptocurrency. 
 
b. UC-1 offered to hand CC-1 $28,000 in cash at the meeting, in order for CC-
1 to launder that cash, but CC-1 told UC-1 that the amount of money was too small, and he would 
not accept less than $50,000 in cash at a time. 
 
c. UC-1 and CC-1 discussed that UC-1 would shortly transfer cash to CC-1, 
and that CC-1 would return the money to him in the form of cryptocurrency and a bank wire. 
 
d. CC-1 and  UC-1  discussed  what  they  would  tell  the  bank  about  the  wire  
transfers.    In  that  context,  CC-1 told  UC-1  to  tell  him  what  UC-1’s  company  was  doing.    I  
understand from my training and experience and my involvement in this investigation that CC-1 
asked  this  question  in  order  to  effectively  deceive  the  bank  when  he  made  a  money  laundering 
transfer to UC-1’s company. 
 
The First Money-Laundering Transaction of $60,000 
 
8. On or about March 22, 2023, DAVID ELIGOOLA, the defendant, met with UC-1.  
That meeting was consensually recorded.  Based on my review of the recording and my discussions 
with other law enforcement officers, I know that the following, in substance and in part, took place 
at the meeting: 
 
a. UC-1  and  ELIGOOLA met  at  a  restaurant.    Shortly  after  meeting  UC-1, 
ELIGOOLA had a short video call with CC-1 in the presence of UC-1.   
 
b. After  the  call,  UC-1  confirmed  that  ELIGOOLA  was  “familiar  with  
everything.”  UC-1 explained that he had “60” on him—i.e., $60,000 in cash—which was part of 
an “initial test” to see “how fast” CC-1 would return the laundered funds.   
 
c. UC-1  requested  that,  in  addition  to  cryptocurrency,  part  of  the  laundered  
funds  be  returned  via  a  bank  wire.    UC-1  stated  that  his  “friend  in  South  America”  was  also  
interested in bank wires.  ELIGOOLA replied that this arrangement should not be a problem.   
 
d. UC-1  said  he would  also  discuss  the  arrangement  with CC-1,  but  did  not  
like talking about such things over the phone.  ELIGOOLA stated he would tell CC-1 what UC-1 
told him.  UC-1 said he would also send CC-1 a note.  
 
e. UC-1 then handed ELIGOOLA a bag containing approximately $60,000 in 
cash.  After receiving the bag, ELIGOOLA left for approximately ten minutes to count the cash.  
CC-1 then returned and confirmed to UC-1 that it was all there. 
 
9. Based  on  my  review  of financial  records  and  my  discussions  with  other  law  
enforcement officers, I know that, several days after the March 22, 2023, meeting between UC-1 
and DAVID ELIGOOLA, the defendant, UC-1 received approximately $45,000 in cryptocurrency 

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and a bank wire for approximately $9,000 into accounts that UC-1 had provided to CC-1, from an 
account held in the name of another individual. These transfers reflected that CC-1 had taken a fee 
of approximately 10% of the $60,000 that CC-1 laundered on UC-1’s behalf.     
 
The Second Money-Laundering Transaction of $100,000  
 
10. On or about April 27, 2023, a coconspirator not named herein (“CC-2”) met with 
an  additional  FBI  undercover  agent  (“UC-2”) for  a  money  exchange  that  had  been  arranged  by  
UC-1 and CC-1.  The   meeting was consensually recorded.  Based on my review of the recording 
and my discussions with other law enforcement officers, I know that the following, in substance 
and in part, took place at the meeting:   
 
a. UC-2 handed CC-2 approximately $100,000 in cash.   
 
11. Based  on  my  review  of financial  records  and  my  discussions  with  other  law  
enforcement  officers,  I  know  that,  several  days  later,  UC-1  received  approximately  $50,000  in  
cryptocurrency and a bank wire for approximately $41,000 into accounts that UC-1 had provided 
to CC-1.    UC-1  therefore  paid  CC-1 a  fee  of  approximately  9%  of  the  $100,000  that  CC-1 
laundered on UC-1’s behalf. 
 
The Third Money-Laundering Transaction of $116,000  
 
12. On or about May 22, 2023, DAVID ELIGOOLA, the defendant, met with UC-2 for 
a  money  exchange  that  had  been  arranged  by  UC-1  and  CC-1.    The   meeting  was  consensually  
recorded.  Based on my review of the recording and my discussions with other law enforcement 
officers, I know that the following, in substance and in part, took place at the meeting: 
 
a. Upon meeting ELIGOOLA in UC-2’s car, UC-2 apologized for being late, 
and explained that UC-2 “had to meet up with our other cartel guys here to get the money.” 
 
b. UC-2  handed ELIGOOLA  a  white  plastic  bag  containing  approximately 
$116,000 in cash.  While still in UC-2’s car, ELIGOOLA proceeded to count the $116,000 in cash.
             
 
13. Based  on  my  review  of  financial  records  and  my  discussions  with  other  law 
enforcement  officers,  I  know  that,  several  days  later,  UC-1  received  approximately  $60,000  in  
cryptocurrency and a bank wire for approximately $45,000 into accounts that UC-1 had provided 
to CC-1.    UC-1  therefore  paid  CC-1 a  fee  of  approximately  9%  of  the  $116,000  that  CC-1 
laundered on UC-1’s behalf. 
 
The Fourth Money-Laundering Transaction of $120,000 
 
14. On or about June 14, 2023, CC-1, and UC-1 met in person in New York, New York.  
That meeting was consensually recorded.  Based on my review of the recording and my discussions 
with other law enforcement officers, I know that the following, in substance and in part, took place 
at the meeting: 
 
a. UC-1 handed CC-1 approximately $120,000 in cash.   
 

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b.CC-1 told UC-1 that he was disappointed that UC-1 was transferring such
small amounts of cash to him, and said that he had expected to be receiving $1 million per week 
from him. 
15.B
ased  on  my  review  of  financial  records  and  my  discussions  with  other  law
enforcement  officers,  I  know  that  several  days  later,  UC-1  received  approximately  $100,000  in  
cryptocurrency and a bank wire for approximately $8,000 into accounts that UC-1 had designated 
to CC-1.    UC-1  therefore  paid  CC-1 a  fee  of  approximately  9%  of  the  $120,000  that  CC-1 
laundered on UC-1’s behalf. 
The Fifth Money-Laundering Transaction of $150,000  
16.On or about July 21, 2023, CC-1, UC-1, and other undercover FBI agents met in
person in Miami, Florida.  That meeting was consensually recorded.  Based on my review of the 
recording and my discussions with other law enforcement officers, I know that the following, in 
substance and in part, took place at the meeting: 
a.UC
-1 handed CC-1 approximately $150,000 in cash.
17.Based  on  my  review  of  financial  records  and  my  discussions  with  other  law
enforcement officers, I know that, several days after  the  July  21,  2023, meeting  between  CC-1, 
UC-1, and other undercover FBI agents, UC-1 received approximately $90,000 in cryptocurrency 
and two bank wires totaling approximately $45,000 into accounts that UC-1 had designated to CC-
1.  UC-1 therefore paid CC-1 a fee of approximately 9% of the $150,000 that CC-1 laundered on
UC-1’s behalf.
W
HEREFORE,  I  respectfully  request  that  a  warrant  be  issued  for  the  arrest  of  DAVID 
ELIGOOLA, the defendant, and that he be arrested, and imprisoned or bailed, as the case may be. 
______________________________ 
L
ARISSA MONTES 
Special Agent 
Federal Bureau of Investigation 
S
worn to me through the transmission of 
this Complaint by reliable electronic  
means, this __ day of April, 2024. 
___________________________________ 
T
HE HONORABLE SARAH NETBURN 
United States Magistrate Judge 
Southern District of New York