
16 Money Laundering: A Guide for Criminal Investigators, Third Edition
of federal law. Robert Allen, the CEO for Gulf Resources,
had another explanation. The company had previously
owed Ogarrio for services performed in closing CAVSA,
he said, and the $100,000 was sent on April 3 to pay
these fees. Ogarrio then immediately loaned money to
the Texas nance committee to make the contribution to
CRP. Just by coincidence, this loan was exactly $100,000.
Allen said he had given Ogarrio a promissory note docu-
menting the loan. One author writes that investigators
were “skeptical” of Allen’s claim, which conicted with