A conspiracy to bribe high ranking Venezuelan officials in exchange for the right to conduct currency transactions is at the center of a number of FCPA related cases. For example, earlier this month Raul Gorrin Belisario, a Venezuelan citizen with a residence in Miami, Florida who had been indicted on charges of conspiracy to violate the FCPA, conspiracy to commit money laundering and nine counts of money laundering pleaded guilty to one count of conspiracy to commit money laundering. The charges and plea were based on the payment of millions of dollars in bribes to Venezuelan officials to secure the rights to conduct foreign currency exchange transactions at favorable rates for the government. U.S. v. Gorrin (S.D.Fla. Unsealed on Nov. 20, 2018).
Now another Venezuelan business man residing in the U.S. has been sentenced to serve three years in prison for his participation in the same conspiracy. Gabriel Arturo Jimenez Aray, the former owner of Banco Peravia, was sentenced following his earlier guilty plea under seal to one count of conspiracy to commit money laundering. Mr. Jamenez admitted as part of the plea to participating in the scheme with Mr. Gorrin and others to acquire Banco Peravia. He then used the bank to launder bribe money. Mr. Jimenez admitted facilitating illegal transactions and bribe payments to foreign officials using bank issued credit cards, cash disbursements, wire transfer and through other transactions, according to his admissions. U.S. v. Jiminez Aray, No. 9:18-cr-80054 (S.D. Fla. Sentenced Nov 29, 2018).
Program: The Fifth Annual Dorsey Federal Enforcement Forum will be held on December 5, 2018. The program, centered on a tech theme and SEC enforcement, includes a keynote address on artificial intelligence and its impact on the legal profession, panels analyzing critical issues facing SEC enforcement, the question of broker protocols, trends in investment adviser inspections, how to conduct an ICO and concludes with an address on cyber-security and internal controls. A holiday gathering follows. The program and registration for it and the party are here or separate registration for the holiday party only here.