Five indicted for money laundering in connection with FCPA offenses in Venezuela

On October 21, 2021, an indictment was unsealed in the US District Court for the Southern District of Florida charging Alvaro Pulido Vargas, Jose Gregorio Vielma-Mora, Emmanuel Enrique Rubio Gonzalez, Carlos Rolando Lizcano Manrique, and Ana Guillermo Luis with laundering the proceeds of a bribery scheme involving contracts obtained through the Comité Local de Abastecimiento y Producción (CLAP) program, a Venezuelan government program for distributing food and medicine. 

According to the indictment, which a federal grand jury returned on October 7, 2021, Pulido, Rubio, Guilermo, Lizcano, and others controlled several companies that through bribery obtained contracts under the CLAP program with Venezuelan state-owned entities.  The indictment alleges that these contracts charged inflated prices the proceeds of which were used to pay bribes to government officials and unjustly enrich the conspirators.  Vielma-Mora, one of the conspirators, was a government official who received bribes as part of the conspiracy and improperly used his position to assist in the award of contracts to the other co-conspirators.  This included contracts with the Comercializadora de Bienes Y Servicios Del Estado Tachira (COBISERTA), which was overseen by Vielma-Mora in his role as governor of the Venezuelan state of Tachira.  The indictment alleges that Vielma-Mora and an unnamed co-conspirator received over $17 million in exchange for Vielma-Mora’s assistance and influence in awarding the contracts.  

The improper payments were transferred through a web of companies and associated bank accounts in several countries, including Antigua, the United Arab Emirates, and the United States.  Additional transactions involving other Venezuelan state-controlled entities and other foreign officials are detailed in the indictment.  Altogether, the indictment lists over $6.3 million alleged to have been transferred into or out of the United States in furtherance of felony violations of the anti-bribery provisions of the Foreign Corrupt Practices Act.

Each of the defendants has been charged with one count of conspiracy to commit money laundering and four counts of money laundering.
 

DOJ press release | Indictment

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