Petition to Deny a Fighter's License to UFC fighter Chael Sonnen

7/27/2019 Petition to Deny a Fighter's License to UFC fighter Chael Sonnen

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1630SOUTH COMMERCESTREET,LAS VEGAS,NV89102TEL (702)385-2131FAX(702)385-5205

WWW.UNITEHERE.ORG FACEBOOK.COM/UNITEHERE@UNITEHERE

July 23, 2013

Ms. LaTeisha Adams

Chairperson, Massachusetts State Athletic Commission

One Ashburton Place

Room 1301

Boston, Massachusetts 02108

Re: Complaint Against the License of Unarmed Combatant, Chael Patrick Sonnen

Dear Ms. Adams:

Chael Patrick Sonnen is scheduled to compete in a professional mixed martial art event

put on by the Ultimate Fighting Championship (UFC) at the TD Garden on August 17, 2013.

We anticipate that Sonnen will apply for a professional unarmed combat license in accordance

with 523 CMR 6.01. We urge that the license be denied because Mr. Sonnen has been

convicted of a crime involving moral turpitude.

The Commission has the authority to deny an application for a license if it finds that the

applicant has performed any act which would, if performed by a licensee, subject the licensee to

discipline pursuant to 523 CMR 20.00 and 21.00. 523 CMR 6.13(1). A license issued by

the Commission may be suspended if the holder is arrested or convicted on a charge involving

moral turpitude. 523 CMR 20.15.

On January 3, 2011, Mr. Sonnen was convicted of money laundering in violation of 18

U.S.C. 1956. SeeUnited States v. Chael Sonnen, Case No. 10-CR-00502 (D. Oregon). Money

laundering is a crime of moral turpitude. Smalley v. Ashcroft, 354 F.3d 332, 339 (5th Cir.2003)

(holding that money laundering is a crime involving moral turpitude);Montalvo v. Mississippi

State Bd. of Medical Licensure, 671 So.2d 53, 56 (1996) (revoking medical license because fraud

against federal government through money laundering was a crime of moral turpitude).

In Smalley, the Court held that money laundering in violation of 18 U.S.C.

1956(a)(3)(B) is a crime of moral turpitude because it involves intentionalconcealment of the

proceeds of unlawful activity (in that case illegal drug money). 354 F.3d at 339. Mr. Sonnen

was convicted of violating 18 U.S.C. 1956(a)(1)(B)(i), which also requires intentional

concealment of the proceeds of unlawful activity:
http://www.unitehere.org/http://www.unitehere.org/http://www.unitehere.org/http://www.unitehere.org/http://www.unitehere.org/http://www.unitehere.org/https://web2.westlaw.com/find/default.wl?mt=122&db=506&tc=-1&rp=%2ffind%2fdefault.wl&findtype=Y&ordoc=2027542317&serialnum=2003916907&vr=2.0&fn=_top&sv=Split&tf=-1&referencepositiontype=S&pbc=D579CACD&referenceposition=339&rs=WLW13.04https://web2.westlaw.com/find/default.wl?mt=122&db=506&tc=-1&rp=%2ffind%2fdefault.wl&findtype=Y&ordoc=2027542317&serialnum=2003916907&vr=2.0&fn=_top&sv=Split&tf=-1&referencepositiontype=S&pbc=D579CACD&referenceposition=339&rs=WLW13.04https://web2.westlaw.com/find/default.wl?mt=122&db=506&tc=-1&rp=%2ffind%2fdefault.wl&findtype=Y&ordoc=2027542317&serialnum=2003916907&vr=2.0&fn=_top&sv=Split&tf=-1&referencepositiontype=S&pbc=D579CACD&referenceposition=339&rs=WLW13.04http://www.unitehere.org/


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(a)(1) Whoever, knowing that the property involved in a financial transaction represents the

proceeds from some form of unlawful activity, conducts or attempts to conduct such a financial

transaction which in fact involves the proceeds of specified unlawful activity

* * *

(B) knowing that the transaction is designed in whole or in part

(i) to conceal or disguise the nature, the location, the source, the ownership, or the

control of the proceeds of specified unlawful activity.

* * *

Shall be sentenced to a fine of not more than $500,000 or twice the value of the property

involved in the transaction, whichever is greater, or imprisonment for not more than twenty

years, or both.

Mr. Sonnen admitted that he knew about and attempted to conceal the illegal source of money he

used in a mortgage transaction. The plea agreement states that Mr. Sonnen plead guilty to the

enclosed Information, which charges the crime of Money Laundering, in violation of Title 18,

United States Code, Section 1956. (Exh. __). The Information alleges:

On or about June 20, 2006, in the District of Oregon, CHAEL PATRICK SONNEN,

defendant herein, did knowingly conduct and attempt to conduct a financial transaction affecting

interstate commerce, to wit, he caused a check in the amount of $69,091.53 to be issued and

negotiated from a bank account at U.S. Bank, which involved the proceeds of a specified

unlawful activity, that is wire fraud. Defendant further knew that the financial transaction was

designed in whole or in part to conceal or disguise the source and nature of the proceeds of wire

fraud, to wit, defendant and others devised and intended to devise a material scheme and artifice

to defraud Decision One Mortgage, and to obtain money and property from Decision One

Mortgage by means of false and fraudulent pretenses, representations and promises, and that

while conducting and attempting to conduct such financial transaction, defendant knew that the

property involved in the financial transaction represented the proceeds of the unlawful activity,

wire fraud.

All in violation of Title 18, United States Code, Section 1956(a)(1)(B)(i).

(Exh. __).

Mr. Sonnens conviction for money laundering should disqualify him from receiving a

professional unarmed combat license in Massachusetts.

We appreciate your time and consideration on this matter.


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Sincerely,

Chris Serres

Research Analyst

UNITE HERE Local 226

Office: 702-386-5231

Cc: Guy Licciardi, Commissioner, Massachusetts State Athletic Commission

Joseph Krowski Jr., Commissioner, Massachusetts State Athletic Commission

Gary L itchfi eld, Commissioner, Massachusetts State Athletic Commission

Joseph Esposito, Commissioner, Massachusetts State Athletic Commission

Thomas G. Gatzuni s, Commissioner, Massachusetts Department of Public Safety

Terr el Harr is, Communications Director, Massachusetts Department of Public Safety

El izabeth D. Nadzo, General Counsel, Massachusetts Department of Public Safety

Documents

Petition to Deny a Fighter's License to UFC fighter Chael Sonnen