Today’s post is about Mr. Alex Nain Saab Moran (“Saab”) and Mr. Alvaro Pulido Vargas (“Pulido”) who could have hidden money at offshore banks; multiple jurisdictions; and in a nominee bank account (i.e. a bank account titled in the name of an intermediary). I listed these three methods for hiding assets at “Red Flags For An Asset Search.” On July 25th Mr. Saab and Mr. Pulido were indicted in Florida for suspected money laundering & an alleged bribery scheme. The alleged scheme is believed to have involved Mr. Saab’s and Mr. Pulido’s bogus invoices which they submitted to the Venezuelan government.
I. SUSPECTED HIDDEN MONEY AT OFFSHORE BANKS
Their July 25th indictment basically alleges Mr. Saab and Mr. Pulido hid the money the Venezuelan government paid them because of the alleged bogus invoices. These payments to Mr. Saab and Mr. Pulido could have been for as much as $350 million U.S. dollars. Mr. Saab and Mr. Pulido are thought to have laundered the payments by transferring the payments from banks in Venezuela to offshore banks in multiple jurisdictions. Mr. Saab and Mr. Pulido may have also hidden money by using a nominee bank account titled in the name of a co-conspirator. Based on the foregoing, money laundering indicators in this case might possibly have been the use of: offshore bank accounts; multiple jurisdictions; and a nominee bank account.
II. HOW THE ALLEGED SCHEME WORKED
In 2011 the Venezuelan government awarded Mr. Saab and Mr. Pulido a contract to construct low-income housing in Venezuela. Mr. Saab and Mr. Pulido then shipped construction materials to Venezuela to build the housing. Mr. Saab’s and Mr. Pulido’s July 25th indictment claims they submitted bogus invoices to the Venezuelan government for these construction materials. The indictment alleges Mr. Saab and Mr. Pulido invoiced the Venezuelan government for multiple shipments of construction materials when they sent only one. Mr. Saab and Mr. Pulido supposedly bribed Venezuelan government officials who photographed one shipment of construction materials in different locations to make the one appear to be multiple shipments. Bribe-taking officials allegedly made sure the Venezuelan government paid Mr. Saab and Mr. Pulido’s bogus invoices. The July 25th indictment also says Mr. Saab’s and Mr Pulido’s alleged bribe payments violated the U.S. Foreign Corrupt Practices Act.
III. MORE ALLEGED WRONGDOING
Finally, Mr. Saab’s and Mr. Pulido’s indictment was not the only thing that happened to them on July 25th. On July 25th the U.S. Treasury Department accused Mr. Saab and Mr. Pulido of stealing money from a food program for the poor in Venezuela. Mr. Saab and Mr. Pulido supposedly hid these illicit proceeds by employing shell companies. Consequently, the U.S Treasury Department put Mr. Saab and Mr. Pulido on one of its sanction lists.
Copyright 2019 Fred L. Abrams