This mid-2021 post highlighted the noticeable trend of the DOJ specifically alleging that an individual violated the FCPA’s anti-bribery provisions, yet not charging the individual with FCPA anti-bribery violations, but rather money laundering 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.
As stated in the DOJ release:
