With increasing frequency the Department of Justice is using money laundering statutes to criminally charge participants in alleged bribery scheme. (See here for the recent post documenting the trend).
In the latest example, yesterday the DOJ announced the unsealing of a June 2020 criminal complaint against agents associated with Odebrecht in connection with the company’s 2016 FCPA enforcement action (see here for the prior post).
According to the complaint, Luis Enrique Martinelli Linares (a citizen of Panama and Italy) and his brother Ricardo Alberto Martinelli Linares (also a citizen of Panama and Italy), both of whom travelled several times to the U.S. during the relevant time period, “participated in the Odebrecht bribery scheme by, among other things, serving as intermediaries for bribe payments and the provision of other things of value that Odebrecht offered and provided to the Panama Government Official. According to the complaint, both defendants “were close relatives” of the Panama Government Official.
