Former Venezuela Treasurer Sentenced for Bribery and Money Laundering

On April 19, 2023, the Department of Justice (DOJ) announced the sentencing of the former National Treasurer of Venezuela and her husband for their roles in a money laundering and international bribery scheme dating back to 2008. According to unsealed court documents, the defendants accepted and laundered over $136 million in bribes from a co-conspirator, Raúl Gorrin Belisario, who owned a national news network.

The former Treasurer, Claudia Patricia Diaz Guillen, was initially convicted on December 15, 2022, of one count of conspiring to commit money laundering and one count of money laundering. Her husband, Adrian José Velásquez, was also convicted of a second count of money laundering. 

Multibillion-Dollar Bribery and Money Laundering Scheme

According to the indictment, between 2008 and 2017, Gorrin paid hundreds of millions of dollars in bribes to Diaz and Velásquez to obtain the rights to conduct foreign currency exchange transactions at favorable rates. To wire the bribe payments, Gorrin used a combination of personal bank accounts and accounts held by companies he beneficially owned and controlled, some of which were located in Switzerland and the Southern District of Florida. 

To conceal the payments, Gorrin and his co-conspirators disguised several bribe payments for the benefit of Diaz by making the payments out to her husband instead. Gorrin’s employees recorded these payments in a spreadsheet, updating it periodically to reflect any changes to certain payments. 

Regarding the laundering tactics used to further obfuscate the bribes, Diaz, Velásquez, and Gorrin purchased and paid expenses related to private jets, yachts, mansions, champion horses, high-end watches, and a designer fashion line. 

As a result of the sentencing, Diaz and Velásquez face 15 years in prison. Gorrin was indicted in August 2018 and remains charged as a co-conspirator in the bribery and money laundering scheme. He is currently a fugitive residing in Venezuela.  

Tackling Cross-Border Corruption 

In June 2021, the Financial Crimes Enforcement Network (FinCEN) highlighted its concern about corruption in its first US government-wide list of national priorities for anti-money laundering and counter-terrorism financing (AML/CFT). Citing the White House’s Memorandum on Establishing the Fight Against Corruption, FinCEN notes that corruption reduces global gross domestic product (GDP) by between 2 and 5 percent.

Countries worldwide have been focusing on anti-corruption initiatives, with the United Nations calling on firms to “develop policies and programs to address all forms of corruption.” In our 2023 global compliance survey, we asked 800 C-suite and senior compliance decision-makers which area of their organization they were most focused on improving regarding AML compliance. Thirty-two percent said anti-bribery and corruption, ahead of adverse media screening and sanctions screening. 

Firms seeking to uplevel this area of their compliance program should ensure they review the outcomes of the 2nd Summit for Democracy, which was co-hosted by the US in March 2023. The summit’s goal was to promote democracy at home and abroad and to develop common approaches to tackling cross-border corruption. 

Key Takeaways

In May 2019, FinCEN issued updated guidance for firms on widespread public corruption

in Venezuela. Compliance staff should review the document, noting the executive orders given to address the situation and the common money laundering typologies used to evade sanctions and facilitate the laundering of proceeds related to corruption, fraud, and embezzlement. 

The advisory also includes a list of red flags to help financial institutions identify and report suspicious activity related to corrupt Venezuelan senior political figures, their family members, and associates. These include: 

• Corrupt Venezuelan senior political figures, their family members, and associates seeking to abuse a US or foreign bank’s wealth management units by using complex financial transactions to move and hide corruption proceeds. 
• Export businesses operating in South Florida – especially those with subsidiaries in Venezuela – that are engaged in the trade of heavy equipment, auto parts, and electronics from Florida to Venezuela pose a higher risk of being facilitators of trade-based money laundering (TBML).
• Cash deposits instead of wire transfers in the accounts of companies involved in Venezuelan government contracts.