Bribery Schemes Lead Instead to Money Laundering Charges

In recent years, the Department of Justice has followed a trend of specifically alleging that an individual violated the FCPA’s anti-bribery provisions, but charging the individual with money laundering rather than FCPA anti-bribery violations. Last week, the DOJ returned to this playbook as it announced the unsealing of an indictment charging three Colombian nationals and two Venezuelan nationals for their alleged roles in laundering the proceeds of contracts to provide food and medicine to Venezuela that were obtained through bribes.