Two Colombian businessmen were charged in an indictment returned today for their alleged roles in laundering the proceeds of violations of the Foreign Corrupt Practices Act (FCPA) in connection with a scheme to pay bribes to take advantage of Venezuela’s government-controlled exchange rate. 

Ariana Fajardo Orshan, U.S. Attorney for the Southern District of Florida, Brian A. Benczkowski, Assistant Attorney General of the Justice Department’s Criminal Division, and Adolphus P. Wright, Special Agent in Charge, Drug Enforcement Administration (DEA), Miami Field Division, made the announcement.

Alex Nain Saab Moran (Saab), 47, and Alvaro Pulido Vargas (Pulido) 55, both citizens of Colombia, were each charged in an eight-count indictment returned in the Southern District of Florida with one count of conspiracy to commit money laundering and seven counts of money laundering.  The indictment also alleges and seeks forfeiture in excess of $350 million representing the amount of funds involved in the violation.

The indictment alleges that beginning in or around November 2011 and continuing until at least September 2015, Saab and Pulido conspired with others to launder the proceeds of an illegal bribery scheme from bank accounts located in Venezuela to and through bank accounts located in the United States.  According to the indictment, Saab and Pulido obtained a contract with the Venezuelan government in November 2011 to build low-income housing units.  The defendants and their co-conspirators then allegedly took advantage of Venezuela’s government-controlled exchange rate, under which U.S. dollars could be obtained at a favorable rate, by submitting false and fraudulent import documents for goods and materials that were never imported into Venezuela and bribing Venezuelan government officials to approve those documents.  The indictment alleges that the unlawful activity was a bribery scheme that violated the FCPA and involved bribery offenses against Venezuela.  It also alleges that meetings in furtherance of the bribe payments occurred in Miami and that Saab and Pulido wired money related to the scheme to bank accounts in the Southern District of Florida.  As a result of the scheme, Saab and Pulido transferred approximately $350 million out of Venezuela, through the United States, to overseas accounts they owned or controlled, the indictment alleges.

According to the indictment, the following property is subject to forfeiture:  (i) a sum of approximately $350,041,500.00 in U.S. currency; (ii) approximately $3,225,593.90 in U.S. currency seized on or about August 20, 2018; (iii) approximately $30,000.00 in U.S. currency seized on or about August 21, 2018; (iv) approximately $3,313,757.69 in U.S. currency seized on or about September 24, 2018; (v) approximately $3,138,844.70 in U.S. currency seized on or about November 5, 2018; and (vi) approximately $2,942,501.37 in U.S. currency seized on or about February 13, 2019.  

An indictment is merely an allegation and the defendants are presumed innocent until proven guilty beyond a reasonable doubt in a court of law.

This case was investigated by DEA with assistance from the FBI’s Miami Field Office and U.S. Immigration and Customs Enforcement’s Homeland Security Investigations Miami Field Office.  Assistant U.S. Attorney Michael B. Nadler of the Southern District of Florida and Trial Attorney John-Alex Romano of the Criminal Division’s Fraud Section are prosecuting the case. 

The Fraud Section is responsible for investigating and prosecuting all FCPA matters.  Additional information about the Justice Department’s FCPA enforcement efforts can be found at www.justice.gov/criminal/fraud/fcpa.

Related court documents and information may be found on the website of the District Court for the Southern District of Florida at www.flsd.uscourts.gov or on http://pacer.flsd.uscourts.gov.