floor-cleaning business called Roman Services, Inc. ("Roman"). Universal then subcontracted with Roman, which assumed responsibility for cleaning seven Jewel stores in the Quad Cities area and in Springfield, Illinois. Between November 1997 and October 1999, Roman employed approximately 40 citizens of the Czech Republic who were not authorized to work in the United States. Universal paid Roman $15,000 per month to perform the cleaning services, and Roman paid its Czech employees from these funds.


4
Kosmel hired his illegal employees by following a general pattern.1 Czech nationals arrived in the United States and obtained class B-2 visas.2 Czech- speaking individuals already residing in the United States then contacted the new arrivals and arranged transportation to meet Kosmel, who transported them to apartments in the Quad Cities and Springfield, Illinois. Kosmelto Davenport, Iowa, all for a $500 fee. In Davenport, Tenev met Kosmel, who allowed Tenev to stay in an apartment in Silvis, Illinois. Kosmel also informed Tenev that he could arrange documentation that would allow Tenev to work lawfully in the United States. Tenev gave Kosmel his visa, and Kosmel hired Tenev to work for Roman. Tenev earned $40 per night cleaning floors at Jewel, minus deductions for rent and other incidentals.


6
Kosmel opened two commercial checking accounts to conduct the financial business of Roman, one under the name "Cleaning Services, Inc." and the other under "Roman Service, Inc." Over a two- year period, Kosmel deposited 42 checks totaling $344,262 in both accounts. From these accounts, Kosmel paid a total of $107,238.50 in wages to his 40 Czech