As discussed in this prior post, in 2018 the DOJ announced criminal charges against Raul Gorrin Belisario, a well-known Venezuelan businessman and described by the DOJ as a citizen and national of Venezuela who at various time periods relevant to the charges was a resident of the U.S. with a residence in Florida.

According to the criminal indictment, Gorrin “offered and agreed to pay bribes to Foreign Official 1 [described as a high-level official with decision-making authority and influence within the Oficina Nacional del Tesoro (ONT), the Venezuelan National Treasury] for purposes of obtaining and retaining business; specifically, influencing and inducing Foreign Official 1 to permit Gorrin to conduct foreign currency exchanges for the Venezuelan government and securing an improper advantage in acquiring the right to conduct such exchange transactions.”

Specifically, the DOJ alleged that Gorrin caused bribe payments totaling at least approximately $94 million to be paid for the benefit of Foreign Official 1, including after Foreign Official 1 left office for introducing him to Foreign Official 2 (also described as a high-level official with decision-making authority and influence within the ONT) and facilitating the continuation of the bribery scheme with Foreign Official 2.

According to the DOJ, in addition to wiring money to and for the benefit of Foreign Official 1, Foreign Official 2, and Co-conspirator 1 (described as the spouse of Foreign Official 2), Gorrin “also purchased and paid expenses related to approximately three jets, a yacht, multiple champion horses, and numerous high-end watches … for Foreign Official 1’s benefit” and “purchased and paid expenses related to jets and a yacht .. for Foreign Official 2 and Co-Conspirator 1’s benefit.”

Gorrin was charged with conspiracy to violate the FCPA’s anti-bribery provisions, conspiracy to commit money laundering, and several substantive money laundering offenses.

This case remains pending and Gorrin is a fugitive.

Last week, the DOJ announced another criminal case against Gorrin “for his role in a $1.2 billion scheme to launder funds corruptly obtained from Venezuela’s state-owned and state-controlled energy company, Petróleos de Venezuela S.A. (PDVSA), in exchange for hundreds of millions in bribe payments to Venezuelan officials.”

As stated in the DOJ release:

“[B]etween 2014 and 2018, Gorrin conspired with others to launder the proceeds of an illegal bribery scheme using the U.S. financial system as well as various bank accounts located abroad. Gorrin and his co-conspirators paid millions of dollars in bribes to high-level Venezuelan officials to obtain foreign currency exchange loan contracts with PDVSA. Gorrin and his co-conspirators subsequently directed the laundering of the illicit proceeds, in part, in the Southern District of Florida, where they purchased real estate, yachts, and other luxury items. To conceal the movement of the bribe payments and illicit funds, Gorrin and his co-conspirators used a series of shell companies and offshore bank accounts.”

In the release, Principal Deputy Assistant Attorney General Nicole Argentieri, head of the Justice Department’s Criminal Division, stated:

“According to the indictment, Gorrin and his co-conspirators paid millions of dollars in bribes to high-ranking foreign officials to secure over $1 billion in ill-gotten gains, which Gorrin and his co-conspirators used to purchase yachts and other luxury items in the United States. Gorrin’s alleged conduct enriched corrupt government officials and exploited the U.S. financial system to facilitate these crimes. Together with our partners, the Criminal Division remains committed to ensuring that the United States is not a safe haven for carrying out money laundering schemes or hiding criminal proceeds.”

U.S. Attorney Markenzy Lapointe for the Southern District of Florida stated:

“This case represents the Southern District of Florida’s continued commitment to combating foreign corruption and holding those who subvert the integrity of the U.S. financial system responsible for their crimes. Our office will continue to partner with the Organized Crime Drug Enforcement Task Forces (OCDETF) to identify, disrupt and prosecute those who launder money to facilitate corruption and carry out their nefarious schemes.”

Executive Associate Director Katrina Berger of Homeland Security Investigations stated:

“This action by HSI working against global illegal activities with our international and domestic partners, significantly upholds the rule of law. This case demonstrates HSI’s global footprint and our commitment to curbing the flow of illicit funds while enforcing U.S. sanctions. It also serves as a stark reminder that crime and corruption will not be tolerated.”