The US Department of Justice has charged two Columbian businessmen with money laundering and conspiracy to commit money laundering with the proceeds of Foreign Corrupt Practices Act violations in Venezuela, in violation of 15 USC 78dd-3 and 18 USC §§ 1956 and 1957.
According to the indictment, Alex Nain Saab Moran and Alvaro Pulido Vargas secured a contract with the Venezuelan government to construct low-income housing, and then bribed officials in the Venezuelan customs administration (the Servicio Nacional Integrado de Administración Aduanera y Tributaria, or SENIAT), the Venezuelan currency exchange authority (the Comisión de Administración de Divisas, or CADIVI), and the Venezuelan national guard (the Guardia Nacional Bolivariana de Venezuela, or GNB), to allow them to submit multiple invoices for a single shipment of goods into Venezuela. The indictment further alleges that Saab and Pulido then exploited the advantageous US dollar exchange rate given by the government to obtain hard currency in payment for the fraudulent invoices. In this way, according to the indictment, Saab and Pulido conspired with others – and even met in Miami in furtherance of the scheme — to launder more than $350 million through US banks between 2011 and 2015.
The US also seeks forfeiture of the allegedly laundered funds pursuant to 18 USC § 982(a)(.1).
In a parallel action, the Office of Foreign Assets Control of the US Department of the Treasury has designated Saab, Pulido and some of their adult children, and has blocked their assets in the US.