On September 22, 2010, the Court of Appeals for the Second Circuit affirmed the conviction and 42-month sentence of Mauricio Alfonso Mazza-Alaluf (“Mazza-Alaluf”), a Chilean national, for conspiring to operate and actually operating an unlicensed money transmitting business based upon his company's use of bank accounts in the United States. United States v. Mazza-Alaluf, 09-3940-cr, 2010 WL 3666717 (2d Cir. Sept. 22, 2010). Mazza-Alaluf was convicted after a two-day bench trial in November 2008 in Manhattan federal court. See United States v. Mazza-Alaluf, 607 F. Supp. 2d 484 (S.D.N.Y. 2009) (trial court's findings of fact and conclusions of law).

Mazza-Alaluf was one of the owners and operators of Turismo Costa Bravo S.A. (“Turismo”), a financial services business based in Santiago, Chile, that, among other things, transferred funds to third parties on behalf of its customers. Turismo made such transfers on behalf of customers making or receiving payments from outside of Chile and also exchanged currency, including dollars, on behalf of tourists in Chile and currency exchange houses in Chile and neighboring countries. At the time of Mazza-Alaluf's arrest in March 2007, Turismo operated three storefront businesses in Santiago. Significantly, Turismo had no offices or employees in the United States, nor did it solicit customers in the United States.