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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. See United 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 intentional concealment 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:

(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. Sonnen’s 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.

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 Litchfield, Commissioner, Massachusetts State Athletic Commission Joseph Esposito, Commissioner, Massachusetts State Athletic Commission Thomas G. Gatzunis, Commissioner, Massachusetts Department of Public Safety Terrel Harris, Communications Director, Massachusetts Department of Public Safety

Elizabeth D. Nadzo, General Counsel, Massachusetts Department of Public Safety