Indictment - US V Gorrin

Case 9:18-cr-80160-WPD Document 3 Entered on FLSD Docket 08/17/2018 Page 1 of 18
FlLEDby+.-o.c.
UNITED STATES DISTRICT COURT

AUG f 6 2018
SOUTHERN DISTRICT OF FLORIDA STEVEN M. LARIMORE
CLERK U. S. DIST CT
8 - 8 0 1-s 0
S. p. 2f Flf\. - MIAMI
.... ~;..":2:1:l
CASEN0.1
18U.s.C.§371 CR . 1M . _ ,. -
18 u.s.c. § 1956(h) - ~0
· , 1TRO-U·LEA~s
18 U.S.C. § 1956(a)(2)(A)
18 u.s.c. § 981(a)(l)(C) . IMTI'HEWMAN
18 U.S.C. § 982(a)(l)
UNITED STATES OF AMERICA,
vs.
FILED UNDER SEAL
RAUL GORRIN BELISARIO,
Defendant.
INDICTMENT
The Grand Jury charges that:
. At all times relevant to this Indictment, unless otherwise specified:
COUNTl
Conspiracy to Violate the Foreign Corrupt Practices Act
(18 u.s.c. § 371)
RELEVANT STATUTORY BACKGROUND
. 1. The Foreign Corrupt Practices Act of 1977, as amended, Title 15, United States
Code, Sections 78dd- l, et seq. (the "FCP A"), was enacted by Congress for the purpose of, among
other things, making it lmlawful to act corruptly in furtherance of an offer, promise, authorization,
or payment of money or anything of value to a foreign government official for the purpose of
assisting in obtaining or retaining business for, or directing business to, any person.
RELEVANT ENTITIES AND INDIVIDUALS
2. Defendant, RAUL GORRIN BELISARIO, was a citizen and national of
Venezuela, who at various periods of the conspiracy was a resident of the United States, having
maintained a residence in Coral Gables, Florida.
3. "Company 1" was a company incorporated and registered in Panama, and is
beneficially controlled by defendant, RAUL GORRIN BELISARIO.
5.. "Company 3" was a company incorporated and registered· in Panama, and is
6. "Foreign Official I" was a citizen and national of Venezuela and served as a high
level official with decision-making authority and influence within the Oficina Nacional del Tesoro
("ONT"); the Venezuelan National Treasury, from in or around 2007 through in or around 2010,
and thus was a "foreign official" as that term is defined in the FCP A, Title 15, United States Code,
Sections 78dd-2 (h)(2)(A) and 78dd-3(f)(2)(A).
7. ''Foreign Official 2" was a citizen and national of Venezuela and served as a high
. level official with decision-making authority and influence within the ONT, from in or around
2011 through in or around 2013, and thus was a "foreign official" as that term is defined in the
FCPA, Title 15, United States Code, Sections 78dd-2 (h)(2)(A) and 78dd-3(f)(2)(A).
8. "Co-Conspirator 1" was the spouse of Foreign Official 2 and a citizen and national
of Venezuela.
9, "Foreign Bailk Official" was a Venezuelan citizen and national and an owner of
"Foreign Bank," a bank located in the Dominican Republic. Foreign Bank Official was a "person"
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and an "agent" of a person as those terms are defined in the FCP A, Title 15, United States Code,
Section 78dd-3(f)(l).
GENERAL ALLEGATIONS
10. Beginning in or around 2008, RAUL GORRIN BELISARIO offered and agreed
to pay bribes to Foreign Official 1 for purposes of obtaining and retaining business; specifically,
influencing and inducing Foreign Official 1 to permit RAUL GORRIN BELISARIO .to conduct
foreign currency exchanges for the Venezuelan government and securing an improper advantage
in acquiring the right to conduct such exchange transactions.
11. · In or around.2010, RAUL GORRIN BELISARIO partnered with Foreign Bank
Official to acquire Foreign Bank to assist in laundering bribes paid to Venezuelan officials and the
proceeds of this and other schemes.
12. From in or around 2011 through in or around 2017, after Foreign Official 1 left
office, RAUL GORRIN BELISARIO caused bribe payments, totaling at least approximately $94
million to be paid for the benefit of Foreign Official 1, for the purpose of (a) continuing to make
the bribe payments referenced in Paragraph 10 above; (b) preventing Foreign Official 1 from
interfering with or impeding the ongoing scheme; and (c) to reward Foreign Official 1 for
introducing RAUL GORRIN BELISARIO to Foreign Official 2 and facilitating the continuation
of the bribery scheme with Foreign Official 2. For example, to carry out the payments to Foreign
Official l;RAUL GORRIN BELISARIO wired approximately $1.78 million from accounts in
Switzerland to accounts in the Southern District of Florida and the Southern District of New York
between in or around December 2012 until in or around June 2013, for the benefit of Foreign
Official I and in furtherance of the scheme. .
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13. RAUL GORRIN BELISARIO used both personal bank accounts and bank
accounts held by companies that he beneficially owned and controlled to wire bribe payments.
14. In or around 2011, when Foreign Official 2 replaced Foreign Official 1 in office,
Foreign Official 1 introduced RAUL GORRIN BELISARIO to Foreign Official 2 and Co-
Conspirator 1.
15. ·Beginning in or around 2011, RAUL GORRIN BELISARIO offered and agreed
to pay bribes to Foreign Official 2 and Co-Conspirator 1 for purposes of influencing and inducing
· Foreign Official 2 to permit RAUL GORRIN BELISARIO to conduct foreign. currency
exchanges for the Venezuelan government and securing an improper advantage in acquiring the
right to conduct such exchange transactions.
16. From in or around 2011 through m or around 2013, RAUL GORRIN
BELISARIO caused bribe payments, totaling at least approximately $65 million to be paid for
. the benefit of Foreign Official 2. For example, to carry out the payments to Foreign Official 2,
RAUL GORRIN BELISARIO wired approximately $8.6 million from accounts in Switzerland
to accounts in the Southern District of Florida between in or around November 2012 until in or
around May 2013 for the benefit of Foreign Official 2 and Co-Conspirator 1 and in furtherance of
the scheme.
17. In exchange for Foreign Official 1 introducing RAUL GORRIN BELISARIO to
Foreign Official 2 and Co-Conspirator 1, while in the Southern District of Florida, RAUL
GORRIN BELISARIO offered and agreed to pay Foreign Official 1 a portion of the profits of
his scheme with Foreign Official 2 and Co-Conspirator 1.
18. In addition to wiring money to and for the benefit of Foreign Official 1, Foreign
Official 2, and Co-Conspirator 1, RAUL GORRIN BELISARIO purchased and paid expenses
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related to approximately three jets, a yacht, multiple champion horses, and numerous high-end
watches in the Southern District of Florida and Southern District of Texas for Foreign Official l's
benefit.
19. ··RAUL GORRIN BELISARIO also purchased and paid expenses related to jets
and a yacht in the Southern District of Florida and Southern District of Texas for Foreign Official
2 and Co-Conspirator l's benefit.
20. RAUL GORRIN BELISARIO received invoices and sent correspondence via e-
mail with vendors for Foreign Official 1, Foreign Official 2, and Co-Conspirator 1, in order to pay
expenses for Foreign Official 1, Foreign Official 2, and Co-Conspirator 1, which RAUL GORRIN
BELISARIO caused to be paid via wire transfer from accounts in Switzerland and elsewhere.
21. RAUL GORRIN BELISARIO's employees tracked these expense payments
r~ferenced in paragraph 20 on spreadsheets and emailed updated spreadsheets to RAUL GORRIN
BELISARIO, Foreign Official 1, and Co-Conspirator 1 reflecting the changes as payments were
made.
THE CONSPIRACY
22. From in or around 2008, through in or around 2017, in Miami-Dade County and
West Palm Beach County, in the Southern District of Florida, and elsewhere, the defendant,
did willfully, that is, with the intent to furtJ:ier the purpose of the conspiracy, and knowingly
combine, conspire, confederate, and agree with others, known and unknown, to commit an offense
against the United States, to wit:
a. being a domestic concern, to willfully and corruptly make use of the mails
and a means and instrumentality of interstate commerce in furtherance of an offer, payment,
5
promise to pay, and authorization of the payment of money, and offered, gifted, promised to give,
and authorized the giving of a thing of value to a foreign official, and to a person, while knowing
that all and a portion of such money and thing of value would be offered, given, and promised,
directly and indirectly, to a foreign official, for purposes of: (A)(i) influencing an act and decision
of such foreign official in his official capacity, (ii) inducing such foreign officialto do and omit to
do an act in violation of the lawful duty of such official, and (iii) securing any improper advantage,
and (B) inducing such foreign official to use his influence with a foreign government and
instrumentality thereof to affect and influence any act and decision of such government and
instrumentality, in order to assist RAUL GORRIN BELISARIO in obtaining and retaining
business for and with, and directing business to, RAUL GORRIN BELISARIO and others, in
violation of Title 15, United States Code, Section 78dd-2.
b. while in the territory of the United States, to willfully and corruptly make
use of the mails and a means and instrumentality of interstate commerce and do an act in
furtherance of an offer, payment, promise to pay, and authorization of the payment of money, and
offered, gifted, promised to give, and authorized the giving of a thing of value to a foreign official,
and to a person, while knowing that all and a portion of such money and thing of value would be
offered, given, and promised, directly and indirectly, to a foreign official, for purposes of: (A)(i)
influencing an act and decision of such foreign official in his official capacity, (ii) inducing such
foreign official to do and omit to do an act in violation of the lawful duty of such official, and (iii)
securing any improper advantage, and (B) inducing such foreign official to use his influence with
a foreign government and instrumentality thereof to affect and influence any act and decision of
such government and instrumentality, in order to assist RAUL GORRIN BELISARIO, and
others, in obtaining and retaining business for and with, and directing business to, RAUL
6
GORRIN BELISARIO and others, in obtaining and retaining business for and with, and directing
business to, a person, in violation of Title 15, United States Code, Section 78dd-3.
PURPOSE OF THE CONSPIRACY
23. It was a purpose of the conspiracy to enrich RAUL GORRIN BELISARIO and
co-conspirators by making and concealing corrupt payments to foreign officials in Venezuela in
order to obtain and retain contracts with the ONT in that country.
MANNER AND MEANS OF THE CONSPIRACY
24. The manner and means by which RAUL GORRIN BELISARIO and his co-
conspirators sought to accomplish the purpose of the conspiracy included, among others, the
following:
a. RAUL GORRIN BELISARIO, together with others, while in the

I
Southern District of Florida and elsewhere, would and did discuss in person making bribe
payments to foreign government officials in Venezuela to secure their assistance in awarding
contracts to RAUL GORRIN BELISARIO.
b. RAUL GORRIN BELISARIO, together with others, while in the
Southern District of Florida and elsewhere, would and did offer to pay, promise to pay, and
authorize the payment of bribes, directly and indirectly, to and for the benefit of foreign officials
in Venezuela, to secure their assistance in awarding business to RAUL GORRIN BELISARIO.
c. RAUL GORRIN BELISARIO, together with others, while in the
Southern District of Florida and elsewhere, would and did discuss in person the manner and means
by which the bribe payments were to be paid.
d. RAUL GORRIN BELISARIO, together with others, while in the
Southern District of Florida and elsewhere, would and did use Company 1, Company 2, and
7
Company 3 bank accounts, in lieu of or in addition to his own personal bank account at HSBC
Private Bank (Suisse) SA, as a conduit for the payment of bribes to foreign government officials
in Venezuela to conceal the bribe payments.
e. RAUL GORRIN BELISARIO, together with others, while in the
Southern District of Florida and elsewhere, would and did cause to be wired certain funds from
the bank accounts of Company 1, Company 2, and Company 3, as well as his own personal bank
account at HSBC Private Bank (Suisse) SA, in Switzerland for the purpose of making payments
to foreign government officials, including Foreign Official 1 and Foreign Official 2, in exchange
for the officials' assistance in awarding business to RAUL GORRIN BELISARIO.
OVERT ACTS
25. In furtherance of the conspiracy and to effect the illegal objects thereof, the
following overt acts, among others, were committed and caused to be committed in the Southern
District of Florida and elsewhere:
(1) In or around 2010, RAUL GORRIN BELISARIO, Foreign Bank Official,
. and others acquired a financial institution in the Dominican Republic for the purpose oflaundering
money and paying bribes to Venezuelan officials.
(2) In or around 2012, RAUL GORRIN BELESARIO met with Foreign
Official 1 in the Southern District of Florida to discuss the payment of bribes.
(3) On or about June 18, 2012, Foreign Official 2 caused a transfer of a bond
from the ONT to Company 1's account in Switzerland, which RAUL GORRIN BELISARIO
was then advised by his bank that it would be liquidated, exchanged, and held in his account and
that the "contact person is [Foreign Official 2]."
8
(4) On or about October 25, 2012, RAUL GORRIN BELISARIO sent an
email with the subject "485,000" to one of his employees and business partners, attaching wire
instructions for a yacht company and stating: "Please make the transfer and charge it to [Co-
Conspirator 1]."
(5) On or about October 29, 2012, RAUL GORRIN BELISARIO caused a
payment of $485,000 to be wired. from Company l's account in Switzerland to the yacht
company's (referenced in paragraph 25 (4)) account in the Southern District of Florida.
(6) On or about November 13, 2012, after receiving an email with the details
·.for the purchase of a yacht for "[Co-Conspirator l]" for $4.35 million, RAUL GORRIN.
BELISARIO caused a payment of $4.35 million to be wired from Company l's account in
Switzerland to a yacht company's account in the Southern District of Florida.
(7) On or about December 11, 2012, Foreign Official 1 e.mailed to RAUL
GORRIN BELISARIO a copy of an invoice for $14,422 for veterinary services and wire
instructions for making the payment.
(8) On or about December 12, 2012, RAUL GORRIN BELISARIO caused a
payment of approximately $15 ,000 to be wired from Company 1's account in Switzerland to the
veterinarian's (referenced in paragraph 25 (7)) account in the Southern District of Florida..
(9) On or about January 29, 2013, after receiving an email with the details for
the purchase of a $1,103,371 security system for Foreign Official l's Caracas, Venezuela, home,
RAUL GORRIN BELISARIO emailed the security system proposal to Foreign Official 1,
addressing Foreign Official 1 as "Boss," and requested his approval.
(10) On or about January 30, 2013, RAUL GORRIN BELISARIO caused a
payment of $1,103,371 to be wired from his personal account at HSBC Private Bank (Suisse) SA
9
in Switzerland to the security company's (referenced in paragraph 25 (9)) account in the Southern
District of Florida.
(11) On or about February 5, 2013, while in Wellington, Florida, Foreign
Official 1 emailed RAUL GORRIN BELISARIO a copy of an invoice for $174,800 from a horse
transport company.
(12) On or about February 7, 2013, RAUL GORRIN BELISARIO caused a
payment of $174,800 to be wired from his personal account at HSBC Private Bank (Suisse) SA in
Switzerland to the horse transport company's (referenced in paragraph 25 (11)) account in New
York.
(13) On or about February 15, 2013, Foreign Official 1 emailed RAUL
GORRIN BELESARIO the identification of the individual who should be paid for expenses
'
related to Foreign Official l's horses.
payment of $150,000 to be wired from Company 1 's account in Switzerland to the account of the
individual to whom horse-related expenses were owed (referenced in paragraph 25 (13)) in the
Southern District of Florida.
(15) On or about March 4, 2013, while in Wellington, Florida, Foreign Official
1 emailed RAUL GORRIN BELISARIO a copy of wire instructions for a horse transport
company.
(16) On or about March 7, 2013, RAUL GORRIN BELISARIO, while in
· Southern District of Florida, caused a payment of $228,768 to be wired from his personal account
.at HSBC Private Bank (Suisse) SA in Switzerland to the horse transport company's (referenced in
paragraph 25 (15)) account in New York.
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(17) On or about March 15, 2013, after receiving an email with the details for
the purchase of a yacht for "[Co-Conspirator l]" for $281,051, RAUL GORRIN BELISARIO
caused a payment of $281,051 to be wired from Company l's account in Switzerland to the yacht
company's account in the Southern District of Florida.
(18) On or about May 17, 2013, RAUL GORRIN BELISARIO caused a
payment of $4 million to be wired from Company 2's account in Switzerland to Co-Conspirator
l's fashion company's account in the Southern District of Florida.
(19) On or about May 29, 2013, Foreign Official 1 emailed RAUL GORRIN
BELISARIO a copy of an invoice for $117,062.15 for home improvement work on Foreign
Official 1's home.
(20) On or about June 6, 2013, RAUL GORRIN BELISARIO caused a
· payment of $117,087.15 to be wired from Company 2's account in Switzerland to the home
improvement company's (referenced in paragraph 25 (19)) account in the Southern District of
Florida.
.All in violation of Title 18, United States Code, Section 371.
COUNT2
Conspiracy to Commit Money Laundering
(18 u.s.c. § 1956(h))
26. Paragraphs l through 21 and 23 through 25 of this Indictment are realleged and
incorporated by reference as though fully set forth herein.
27. From in ocaround 2008, through in or around 2017, in Miami-Dade County and
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did knowingly and willfully combine, conspire, confederate, and agree with each other and with
others known and unknown to the Grand Jury to violate Title 18, United States Code, Section
1956(a)(2)(A), that is, to knowingly transport, transmit, and transfer a monetary instrument and
funds to a place in the United States from and through a place outside of the United States with
the intent to promote the carrying on of specified unlawful activity, that is, (a) violations of the
Foreign Corrupt Practices Act under Title 15, United States Code, Section 78dd-2 and 78dd-3, and
(b) offenses against a foreign nation involving bribery of a public official and the misappropriation,
theft, and embezzlement of public funds by or for the benefit of a public official, in violation of
Title 18, Uriited States Code, Section 1956(a)(2)(A), to wit, RAUL GORRIN BELESARIO
agreed to transport, transmit, transfer, and cause to be transported, transmitted, and transferred
funds from Switzerland to the United States, in furtherance of a scheme to pay and offer money
and other things of value to foreign officials in Venezuela, including Foreign Official 1 and Foreign
Official 2, to obtain and retain business for RAUL GORRIN BELESARIO.
All in violation of Title 18, United States Code, Section 1956(h).
COUNTS3-ll
Laundering of Monetary Instruments
(18 U.S.C. § 1956(a)(2)(A))
28. Paragraphs 1 through 21 and 23 through 25 of this Indictment are realleged and
29. From in or around 2008, through in or around 2017, in Miami-Dade"County and
knowingly transported, transmitted, and transferred, and aided and abetted the transport,
transmission, and transfer of, and attempted to transport, transmit, and transfer, a monetary
12
instrument and funds to a place in the United States from and through a place outside the United
States, with the intent to promote the carrying on of specified unlawful activity, that is, (a)
violations of the Foreign Corrupt Practices Act under Title 15, United States Code, Sections 78dd-
. 2 and 78dd-3, and (b) offenses against a foreign nation, specifically Venezuela, involving bribery
of a public official and the misappropriation, theft, and embezzlement of public funds by or for the
benefit of a public official, in violation of Title 18, United States Code, Section 1956(a)(2)(A),
that is, on or about the following dates, as set forth in each count:
...
Count Approximate Date Financial Transaction '.
3 November 13, 2012 Wire transfer in the amount of approximately $4.35 million
from an account in Switzerland to an account located in the
United States, specifically in the Southern District of Florida.
4 December 12, 2012 Wire transfer in the amount of approximately $15,000 from
an account in Switzerland to an account located in the United
States, specifically the Southern District of Florida.
5 January 30, 2013 Wire transfer in the amount of approximately $1,103,371
6 February 7, 2013 Wire transfer in the amount of approximately $17 4,800 from
States,' specifically in the Southern District of New York.
7 February 25, 2013 Wire transfer in the amount of approximately $150,000 from
States, specifically in the Southern District of Florida.
8 March 7, 2013 Wire transfer in the amount of approximately $228,768 from
States, specifically in Southern District of New York.
States, specifically in Southern District of Florida.
10 May 17, 2013 Wire transfer in the amount of approximately $4 million from
11 June 6, 2013 Wire transfer in the amount of approximately $117,087.15
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In violation of Title 18, United States Code, Sections 1956(a)(2)(A) and 2.
FORFEITURE
(18 U.S.C. §§ 981(a)(l)(C) and 982(a)(l))
1. The allegations contained in this Indictment are re-alleged and incorporated by
. reference as though fully set forth herein for the purpose of alleging forfeiture to the United States
of certain property in which the defendant, RAUL GORRIN BELISARIO, has an interest.
2. Upon conviction of a violation of Title 15, United States Code, Sections 78dd-2
and/or 78dd-3, or conspiracy to commit such violation, as alleged in this Indictment, the defendant
shall forfeit to the United States any property, real or personal, which constitutes or is derived from
proceeds traceable to such offense, pursuant to Title 18, United States Code, Section 981(a)(l)(C),
which is made criminally applicable by Title 28, United States Code, Section 2461(c).
3. Upon conviction of a violation of Title 18, United States Code, Section 1956, as
alleged in this Indictment, the defendan(§hall forfeit to the United States any property, real or
person~l, involved in such offense, and/or any property traceable to such property, pursuant to
Title 18, United States Code, Section 982(a)(l).
4. .If any property subject to forfeiture, as a result of any act or omission of the
defendant,
(a) cannot be located upon the exercise of due diligence,
(b) has been transferred or sold to, or deposited with, a third party,
(c) has been placed beyond the jurisdiction of the Court,
(d) has been substantially diminished in value, or
(e) has been commingled with other property which cannot be divided without
difficulty,
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the United States shall be entitled to forfeiture of substitute property under the provisions of Title
21, United States Code, Section 853(p), as incorporated by Title 18, United States Code, Section
982(b)(l).
5. The substitute property subject to forfeiture includes, but is not limited to, the
following real property, together with all appurtenances, improvements, fixtures, easements and
attachments, therein and/or thereon:
(1) 1241 Placetas Avenue, Coral Gables Florida 33146;
(2) 140 Paloma Drive, Coral Gables, Florida 33143;
(3) 144 Isla Dorada Boulevard, Coral Gables, Florida 33143;
(4) 18555 Collins Avenue, Unit 4401, Sunny Isles Beach, Florida 33160;
(5) 21055 Yacht Club Drive, Unit 2602,Aventura, Florida 33180;
(6) 21055 Yacht Club Drive, Unit 503, Aventura, Florida 33180;
(7) 4100 Salzedo Street, Unit 804, Coral Gables, Florida 33146;
(8) 4100 Salzedo Street, Unit 904, Coral Gables~ Florida 33146;
(16) 4100 SalzedG Street, Unit 909, Coral Gables, Florida 33146;
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(18) 20 W. 53rd St, 47A, New York, New York 10019;
(19) 310 E. 53th Street, Apt 24C, New York, New York 10022;
(20), 330 E. 57th Street, Apt 9, New York, New York 10022;
(21) 330 E. 57th Street, Apt 11, New York, New York 10022;
--
(23) 60 Riverside Boulevard, PH 3702, New York, NY 10069; and
(24) 60 Riverside Boulevard, PH 3602, New York, NY 10069.
All pursuant to Title 18, United States Code, Sections 981(a)(l)(C) and 982(a)(l) and the
procedures set forth in Title 21, United States Code, Section 853, as incorporated by Title 18,
United States Code, Section 982(b)(l) and Title 28, United States Code, Section 2461(c).
1
RANDY A. HUMMEL SANDRA L. MOSER
ACTING UNITED STATES ATTORNEY ACTING CHIEF, FRAUD SECTION
ACTING UNDER AUTHORITY CONFERRED CRIMINAL DIVISION
BY 28 U.S.C. § 515
v~
Paul A. Hayden
Trial Attorneys
16
UNITED STATES
Case 9:18-cr-80160-WPD Document DISTRICT
3 DISTRICT
Entered on COURT
SOUTHERN OFFLSD Docket 08/17/2018 Page 17 of 18
FLORIDA
UNITED STATES OF AMERICA CASE NO.

v.
RAUL GORRIN BELISARIO CERTIFICATE OF TRIAL ATTORNEY*
Defendant.
Superseding Case Information:
Court Division: (select One) New Defendant(s) Yes No

Number of New Defendants
Miami _ _ Key West Total number of counts
FTL __x_ WPB FTP
I do hereby certify that:
'
1. I have carefully considered the allegations of the indictment, the number of defendants, the number
of probable witnesses and the legal complexities of the Indictment/Information attached hereto.
2. I am aware that the information supplied on this statement will be relied upon by the Judges of this
Court in setting their calendars and scheduling criminal trials under the mandate of the Speedy Trial
Act, Title 28 U.S.C. Section 3161.
3. Interpreter: (Yes or No) YES
List language and/or dialect SPANISH
4. This case will take 14 days for the parties to try.
5. Please check appropriate category and type of offense listed below:
(Check only one) (Check only one)
I 0 to 5 days Petty
II 6 to 10 days Minor
III 11 to 20 days x Misdem.
IV 21 to 60 days Felony x
v 61 days and over
6. Has this case been previously filed in this District Court? (Yes or No) NO
If yes:
Judge: Case No.
(Attach copy of dispositive order)
Has a complaint been filed in this matter? (Yes or No) NO ,
If yes:
Magistrate Case No.
Related Miscellaneous numbers:
Defendant(s) in federal custody as of
Defendant(s) in state custody as of
Rule 20 from the District of
Is this a potential death penalty case? (Yes or No) NO
7. · Does this case originate from a matter pending in the Northern Region of the U.S. Attorney's Office
prior to October 14, 2003? Yes No X
*Penalty Sheet(s) attached REV 5/3/17


SOUTHERN DISTRICT OF FLORIDA
PENALTY SHEET
Defendant's Name: RAUL GORRIN BELISARIO
Count#l:
Title 18 United States Code 371
*Max. Penalty: Five (5) years' imprisonment
Counts #2:
Title 18, United States Code, 1956(h)
*Max. Penalty: Twenty (20) years' imprisonment as to each count
Count #3-11:
Title 18, United States ~ode, 1956(a)(2)(A)
*Max. Penalty: Twenty (20) years' imprisonment
*Refers only to possible term of incarceration, does not in dude possible fines, restitution,
special assessments, parole terms, or forfeitures that may be applicable.
Case 9:18-cr-80160-WPD Document 3-1 Entered on FLSD Docket 08/17/2018 Page 1 of 18
FlLEDby+.-o.c.

AUG f 6 2018
SOUTHERN DISTRICT OF FLORIDA STEVEN M. LARIMORE
CLERK U. S. DIST CT
8 - 8 0 1-s 0
S. p. 2f Flf\. - MIAMI
.... ~;..":2:1:l
CASEN0.1
18U.s.C.§371 CR . 1M . _ ,. -
18 u.s.c. § 1956(h) - ~0
· , 1TRO-U·LEA~s
18 U.S.C. § 1956(a)(2)(A)
18 u.s.c. § 981(a)(l)(C) . IMTI'HEWMAN
18 U.S.C. § 982(a)(l)
UNITED STATES OF AMERICA,
vs.
FILED UNDER SEAL
Defendant.
INDICTMENT
The Grand Jury charges that:
. At all times relevant to this Indictment, unless otherwise specified:
COUNTl
(18 u.s.c. § 371)
RELEVANT STATUTORY BACKGROUND
. 1. The Foreign Corrupt Practices Act of 1977, as amended, Title 15, United States
Code, Sections 78dd- l, et seq. (the "FCP A"), was enacted by Congress for the purpose of, among
other things, making it lmlawful to act corruptly in furtherance of an offer, promise, authorization,
or payment of money or anything of value to a foreign government official for the purpose of
assisting in obtaining or retaining business for, or directing business to, any person.
RELEVANT ENTITIES AND INDIVIDUALS
2. Defendant, RAUL GORRIN BELISARIO, was a citizen and national of
Venezuela, who at various periods of the conspiracy was a resident of the United States, having
maintained a residence in Coral Gables, Florida.
5.. "Company 3" was a company incorporated and registered· in Panama, and is
6. "Foreign Official I" was a citizen and national of Venezuela and served as a high
level official with decision-making authority and influence within the Oficina Nacional del Tesoro
("ONT"); the Venezuelan National Treasury, from in or around 2007 through in or around 2010,
and thus was a "foreign official" as that term is defined in the FCP A, Title 15, United States Code,
Sections 78dd-2 (h)(2)(A) and 78dd-3(f)(2)(A).
7. ''Foreign Official 2" was a citizen and national of Venezuela and served as a high
. level official with decision-making authority and influence within the ONT, from in or around
2011 through in or around 2013, and thus was a "foreign official" as that term is defined in the
FCPA, Title 15, United States Code, Sections 78dd-2 (h)(2)(A) and 78dd-3(f)(2)(A).
8. "Co-Conspirator 1" was the spouse of Foreign Official 2 and a citizen and national
of Venezuela.
9, "Foreign Bailk Official" was a Venezuelan citizen and national and an owner of
"Foreign Bank," a bank located in the Dominican Republic. Foreign Bank Official was a "person"
2
and an "agent" of a person as those terms are defined in the FCP A, Title 15, United States Code,
Section 78dd-3(f)(l).
GENERAL ALLEGATIONS
10. Beginning in or around 2008, RAUL GORRIN BELISARIO offered and agreed
to pay bribes to Foreign Official 1 for purposes of obtaining and retaining business; specifically,
influencing and inducing Foreign Official 1 to permit RAUL GORRIN BELISARIO .to conduct
foreign currency exchanges for the Venezuelan government and securing an improper advantage
in acquiring the right to conduct such exchange transactions.
11. · In or around.2010, RAUL GORRIN BELISARIO partnered with Foreign Bank
Official to acquire Foreign Bank to assist in laundering bribes paid to Venezuelan officials and the
proceeds of this and other schemes.
12. From in or around 2011 through in or around 2017, after Foreign Official 1 left
office, RAUL GORRIN BELISARIO caused bribe payments, totaling at least approximately $94
million to be paid for the benefit of Foreign Official 1, for the purpose of (a) continuing to make
the bribe payments referenced in Paragraph 10 above; (b) preventing Foreign Official 1 from
interfering with or impeding the ongoing scheme; and (c) to reward Foreign Official 1 for
introducing RAUL GORRIN BELISARIO to Foreign Official 2 and facilitating the continuation
of the bribery scheme with Foreign Official 2. For example, to carry out the payments to Foreign
Official l;RAUL GORRIN BELISARIO wired approximately $1.78 million from accounts in
Switzerland to accounts in the Southern District of Florida and the Southern District of New York
between in or around December 2012 until in or around June 2013, for the benefit of Foreign
Official I and in furtherance of the scheme. .
3
13. RAUL GORRIN BELISARIO used both personal bank accounts and bank
accounts held by companies that he beneficially owned and controlled to wire bribe payments.
14. In or around 2011, when Foreign Official 2 replaced Foreign Official 1 in office,
Foreign Official 1 introduced RAUL GORRIN BELISARIO to Foreign Official 2 and Co-
Conspirator 1.
15. ·Beginning in or around 2011, RAUL GORRIN BELISARIO offered and agreed
to pay bribes to Foreign Official 2 and Co-Conspirator 1 for purposes of influencing and inducing
· Foreign Official 2 to permit RAUL GORRIN BELISARIO to conduct foreign. currency
exchanges for the Venezuelan government and securing an improper advantage in acquiring the
right to conduct such exchange transactions.
16. From in or around 2011 through m or around 2013, RAUL GORRIN
BELISARIO caused bribe payments, totaling at least approximately $65 million to be paid for
. the benefit of Foreign Official 2. For example, to carry out the payments to Foreign Official 2,
RAUL GORRIN BELISARIO wired approximately $8.6 million from accounts in Switzerland
to accounts in the Southern District of Florida between in or around November 2012 until in or
around May 2013 for the benefit of Foreign Official 2 and Co-Conspirator 1 and in furtherance of
the scheme.
17. In exchange for Foreign Official 1 introducing RAUL GORRIN BELISARIO to
Foreign Official 2 and Co-Conspirator 1, while in the Southern District of Florida, RAUL
GORRIN BELISARIO offered and agreed to pay Foreign Official 1 a portion of the profits of
his scheme with Foreign Official 2 and Co-Conspirator 1.
18. In addition to wiring money to and for the benefit of Foreign Official 1, Foreign
Official 2, and Co-Conspirator 1, RAUL GORRIN BELISARIO purchased and paid expenses
4
related to approximately three jets, a yacht, multiple champion horses, and numerous high-end
watches in the Southern District of Florida and Southern District of Texas for Foreign Official l's
benefit.
19. ··RAUL GORRIN BELISARIO also purchased and paid expenses related to jets
and a yacht in the Southern District of Florida and Southern District of Texas for Foreign Official
2 and Co-Conspirator l's benefit.
20. RAUL GORRIN BELISARIO received invoices and sent correspondence via e-
mail with vendors for Foreign Official 1, Foreign Official 2, and Co-Conspirator 1, in order to pay
expenses for Foreign Official 1, Foreign Official 2, and Co-Conspirator 1, which RAUL GORRIN
BELISARIO caused to be paid via wire transfer from accounts in Switzerland and elsewhere.
21. RAUL GORRIN BELISARIO's employees tracked these expense payments
r~ferenced in paragraph 20 on spreadsheets and emailed updated spreadsheets to RAUL GORRIN
BELISARIO, Foreign Official 1, and Co-Conspirator 1 reflecting the changes as payments were
made.
THE CONSPIRACY
22. From in or around 2008, through in or around 2017, in Miami-Dade County and
did willfully, that is, with the intent to furtJ:ier the purpose of the conspiracy, and knowingly
combine, conspire, confederate, and agree with others, known and unknown, to commit an offense
against the United States, to wit:
a. being a domestic concern, to willfully and corruptly make use of the mails
and a means and instrumentality of interstate commerce in furtherance of an offer, payment,
5
promise to pay, and authorization of the payment of money, and offered, gifted, promised to give,
and authorized the giving of a thing of value to a foreign official, and to a person, while knowing
that all and a portion of such money and thing of value would be offered, given, and promised,
directly and indirectly, to a foreign official, for purposes of: (A)(i) influencing an act and decision
of such foreign official in his official capacity, (ii) inducing such foreign officialto do and omit to
do an act in violation of the lawful duty of such official, and (iii) securing any improper advantage,
and (B) inducing such foreign official to use his influence with a foreign government and
instrumentality thereof to affect and influence any act and decision of such government and
instrumentality, in order to assist RAUL GORRIN BELISARIO in obtaining and retaining
business for and with, and directing business to, RAUL GORRIN BELISARIO and others, in
violation of Title 15, United States Code, Section 78dd-2.
b. while in the territory of the United States, to willfully and corruptly make
use of the mails and a means and instrumentality of interstate commerce and do an act in
furtherance of an offer, payment, promise to pay, and authorization of the payment of money, and
offered, gifted, promised to give, and authorized the giving of a thing of value to a foreign official,
and to a person, while knowing that all and a portion of such money and thing of value would be
offered, given, and promised, directly and indirectly, to a foreign official, for purposes of: (A)(i)
influencing an act and decision of such foreign official in his official capacity, (ii) inducing such
foreign official to do and omit to do an act in violation of the lawful duty of such official, and (iii)
securing any improper advantage, and (B) inducing such foreign official to use his influence with
a foreign government and instrumentality thereof to affect and influence any act and decision of
such government and instrumentality, in order to assist RAUL GORRIN BELISARIO, and
others, in obtaining and retaining business for and with, and directing business to, RAUL
6
GORRIN BELISARIO and others, in obtaining and retaining business for and with, and directing
business to, a person, in violation of Title 15, United States Code, Section 78dd-3.
PURPOSE OF THE CONSPIRACY
23. It was a purpose of the conspiracy to enrich RAUL GORRIN BELISARIO and
co-conspirators by making and concealing corrupt payments to foreign officials in Venezuela in
order to obtain and retain contracts with the ONT in that country.
MANNER AND MEANS OF THE CONSPIRACY
24. The manner and means by which RAUL GORRIN BELISARIO and his co-
conspirators sought to accomplish the purpose of the conspiracy included, among others, the
following:
a. RAUL GORRIN BELISARIO, together with others, while in the

I
Southern District of Florida and elsewhere, would and did discuss in person making bribe
payments to foreign government officials in Venezuela to secure their assistance in awarding
contracts to RAUL GORRIN BELISARIO.
b. RAUL GORRIN BELISARIO, together with others, while in the
Southern District of Florida and elsewhere, would and did offer to pay, promise to pay, and
authorize the payment of bribes, directly and indirectly, to and for the benefit of foreign officials
in Venezuela, to secure their assistance in awarding business to RAUL GORRIN BELISARIO.
c. RAUL GORRIN BELISARIO, together with others, while in the
Southern District of Florida and elsewhere, would and did discuss in person the manner and means
by which the bribe payments were to be paid.
d. RAUL GORRIN BELISARIO, together with others, while in the
Southern District of Florida and elsewhere, would and did use Company 1, Company 2, and
7
Company 3 bank accounts, in lieu of or in addition to his own personal bank account at HSBC
Private Bank (Suisse) SA, as a conduit for the payment of bribes to foreign government officials
in Venezuela to conceal the bribe payments.
e. RAUL GORRIN BELISARIO, together with others, while in the
Southern District of Florida and elsewhere, would and did cause to be wired certain funds from
the bank accounts of Company 1, Company 2, and Company 3, as well as his own personal bank
account at HSBC Private Bank (Suisse) SA, in Switzerland for the purpose of making payments
to foreign government officials, including Foreign Official 1 and Foreign Official 2, in exchange
for the officials' assistance in awarding business to RAUL GORRIN BELISARIO.
OVERT ACTS
25. In furtherance of the conspiracy and to effect the illegal objects thereof, the
following overt acts, among others, were committed and caused to be committed in the Southern
District of Florida and elsewhere:
(1) In or around 2010, RAUL GORRIN BELISARIO, Foreign Bank Official,
. and others acquired a financial institution in the Dominican Republic for the purpose oflaundering
money and paying bribes to Venezuelan officials.
(2) In or around 2012, RAUL GORRIN BELESARIO met with Foreign
Official 1 in the Southern District of Florida to discuss the payment of bribes.
(3) On or about June 18, 2012, Foreign Official 2 caused a transfer of a bond
from the ONT to Company 1's account in Switzerland, which RAUL GORRIN BELISARIO
was then advised by his bank that it would be liquidated, exchanged, and held in his account and
that the "contact person is [Foreign Official 2]."
8
(4) On or about October 25, 2012, RAUL GORRIN BELISARIO sent an
email with the subject "485,000" to one of his employees and business partners, attaching wire
instructions for a yacht company and stating: "Please make the transfer and charge it to [Co-
Conspirator 1]."
(5) On or about October 29, 2012, RAUL GORRIN BELISARIO caused a
payment of $485,000 to be wired. from Company l's account in Switzerland to the yacht
company's (referenced in paragraph 25 (4)) account in the Southern District of Florida.
(6) On or about November 13, 2012, after receiving an email with the details
·.for the purchase of a yacht for "[Co-Conspirator l]" for $4.35 million, RAUL GORRIN.
BELISARIO caused a payment of $4.35 million to be wired from Company l's account in
Switzerland to a yacht company's account in the Southern District of Florida.
(7) On or about December 11, 2012, Foreign Official 1 e.mailed to RAUL
GORRIN BELISARIO a copy of an invoice for $14,422 for veterinary services and wire
instructions for making the payment.
(8) On or about December 12, 2012, RAUL GORRIN BELISARIO caused a
payment of approximately $15 ,000 to be wired from Company 1's account in Switzerland to the
veterinarian's (referenced in paragraph 25 (7)) account in the Southern District of Florida..
(9) On or about January 29, 2013, after receiving an email with the details for
the purchase of a $1,103,371 security system for Foreign Official l's Caracas, Venezuela, home,
RAUL GORRIN BELISARIO emailed the security system proposal to Foreign Official 1,
addressing Foreign Official 1 as "Boss," and requested his approval.
(10) On or about January 30, 2013, RAUL GORRIN BELISARIO caused a
payment of $1,103,371 to be wired from his personal account at HSBC Private Bank (Suisse) SA
9
in Switzerland to the security company's (referenced in paragraph 25 (9)) account in the Southern
District of Florida.
(11) On or about February 5, 2013, while in Wellington, Florida, Foreign
Official 1 emailed RAUL GORRIN BELISARIO a copy of an invoice for $174,800 from a horse
transport company.
payment of $174,800 to be wired from his personal account at HSBC Private Bank (Suisse) SA in
Switzerland to the horse transport company's (referenced in paragraph 25 (11)) account in New
York.
(13) On or about February 15, 2013, Foreign Official 1 emailed RAUL
GORRIN BELESARIO the identification of the individual who should be paid for expenses
'
related to Foreign Official l's horses.
payment of $150,000 to be wired from Company 1 's account in Switzerland to the account of the
individual to whom horse-related expenses were owed (referenced in paragraph 25 (13)) in the
Southern District of Florida.
(15) On or about March 4, 2013, while in Wellington, Florida, Foreign Official
1 emailed RAUL GORRIN BELISARIO a copy of wire instructions for a horse transport
company.
(16) On or about March 7, 2013, RAUL GORRIN BELISARIO, while in
· Southern District of Florida, caused a payment of $228,768 to be wired from his personal account
.at HSBC Private Bank (Suisse) SA in Switzerland to the horse transport company's (referenced in
paragraph 25 (15)) account in New York.
10
(17) On or about March 15, 2013, after receiving an email with the details for
the purchase of a yacht for "[Co-Conspirator l]" for $281,051, RAUL GORRIN BELISARIO
caused a payment of $281,051 to be wired from Company l's account in Switzerland to the yacht
company's account in the Southern District of Florida.
(18) On or about May 17, 2013, RAUL GORRIN BELISARIO caused a
payment of $4 million to be wired from Company 2's account in Switzerland to Co-Conspirator
l's fashion company's account in the Southern District of Florida.
(19) On or about May 29, 2013, Foreign Official 1 emailed RAUL GORRIN
BELISARIO a copy of an invoice for $117,062.15 for home improvement work on Foreign
Official 1's home.
(20) On or about June 6, 2013, RAUL GORRIN BELISARIO caused a
· payment of $117,087.15 to be wired from Company 2's account in Switzerland to the home
improvement company's (referenced in paragraph 25 (19)) account in the Southern District of
Florida.
.All in violation of Title 18, United States Code, Section 371.
COUNT2
(18 u.s.c. § 1956(h))
26. Paragraphs l through 21 and 23 through 25 of this Indictment are realleged and
27. From in ocaround 2008, through in or around 2017, in Miami-Dade County and
11
did knowingly and willfully combine, conspire, confederate, and agree with each other and with
others known and unknown to the Grand Jury to violate Title 18, United States Code, Section
1956(a)(2)(A), that is, to knowingly transport, transmit, and transfer a monetary instrument and
funds to a place in the United States from and through a place outside of the United States with
the intent to promote the carrying on of specified unlawful activity, that is, (a) violations of the
Foreign Corrupt Practices Act under Title 15, United States Code, Section 78dd-2 and 78dd-3, and
(b) offenses against a foreign nation involving bribery of a public official and the misappropriation,
theft, and embezzlement of public funds by or for the benefit of a public official, in violation of
Title 18, Uriited States Code, Section 1956(a)(2)(A), to wit, RAUL GORRIN BELESARIO
agreed to transport, transmit, transfer, and cause to be transported, transmitted, and transferred
funds from Switzerland to the United States, in furtherance of a scheme to pay and offer money
and other things of value to foreign officials in Venezuela, including Foreign Official 1 and Foreign
Official 2, to obtain and retain business for RAUL GORRIN BELESARIO.
All in violation of Title 18, United States Code, Section 1956(h).
COUNTS3-ll
(18 U.S.C. § 1956(a)(2)(A))
28. Paragraphs 1 through 21 and 23 through 25 of this Indictment are realleged and
29. From in or around 2008, through in or around 2017, in Miami-Dade"County and
knowingly transported, transmitted, and transferred, and aided and abetted the transport,
transmission, and transfer of, and attempted to transport, transmit, and transfer, a monetary
12
instrument and funds to a place in the United States from and through a place outside the United
States, with the intent to promote the carrying on of specified unlawful activity, that is, (a)
violations of the Foreign Corrupt Practices Act under Title 15, United States Code, Sections 78dd-
. 2 and 78dd-3, and (b) offenses against a foreign nation, specifically Venezuela, involving bribery
of a public official and the misappropriation, theft, and embezzlement of public funds by or for the
benefit of a public official, in violation of Title 18, United States Code, Section 1956(a)(2)(A),
that is, on or about the following dates, as set forth in each count:
...
Count Approximate Date Financial Transaction '.
3 November 13, 2012 Wire transfer in the amount of approximately $4.35 million
4 December 12, 2012 Wire transfer in the amount of approximately $15,000 from
States, specifically the Southern District of Florida.
5 January 30, 2013 Wire transfer in the amount of approximately $1,103,371
6 February 7, 2013 Wire transfer in the amount of approximately $17 4,800 from
States,' specifically in the Southern District of New York.
7 February 25, 2013 Wire transfer in the amount of approximately $150,000 from
States, specifically in Southern District of New York.
States, specifically in Southern District of Florida.
10 May 17, 2013 Wire transfer in the amount of approximately $4 million from
11 June 6, 2013 Wire transfer in the amount of approximately $117,087.15
13
In violation of Title 18, United States Code, Sections 1956(a)(2)(A) and 2.
FORFEITURE
(18 U.S.C. §§ 981(a)(l)(C) and 982(a)(l))
1. The allegations contained in this Indictment are re-alleged and incorporated by
. reference as though fully set forth herein for the purpose of alleging forfeiture to the United States
of certain property in which the defendant, RAUL GORRIN BELISARIO, has an interest.
2. Upon conviction of a violation of Title 15, United States Code, Sections 78dd-2
and/or 78dd-3, or conspiracy to commit such violation, as alleged in this Indictment, the defendant
shall forfeit to the United States any property, real or personal, which constitutes or is derived from
proceeds traceable to such offense, pursuant to Title 18, United States Code, Section 981(a)(l)(C),
which is made criminally applicable by Title 28, United States Code, Section 2461(c).
3. Upon conviction of a violation of Title 18, United States Code, Section 1956, as
alleged in this Indictment, the defendan(§hall forfeit to the United States any property, real or
person~l, involved in such offense, and/or any property traceable to such property, pursuant to
Title 18, United States Code, Section 982(a)(l).
4. .If any property subject to forfeiture, as a result of any act or omission of the
defendant,
(a) cannot be located upon the exercise of due diligence,
(b) has been transferred or sold to, or deposited with, a third party,
(c) has been placed beyond the jurisdiction of the Court,
(d) has been substantially diminished in value, or
(e) has been commingled with other property which cannot be divided without
difficulty,
14
the United States shall be entitled to forfeiture of substitute property under the provisions of Title
21, United States Code, Section 853(p), as incorporated by Title 18, United States Code, Section
982(b)(l).
5. The substitute property subject to forfeiture includes, but is not limited to, the
following real property, together with all appurtenances, improvements, fixtures, easements and
attachments, therein and/or thereon:
(1) 1241 Placetas Avenue, Coral Gables Florida 33146;
(2) 140 Paloma Drive, Coral Gables, Florida 33143;
(3) 144 Isla Dorada Boulevard, Coral Gables, Florida 33143;
(4) 18555 Collins Avenue, Unit 4401, Sunny Isles Beach, Florida 33160;
(5) 21055 Yacht Club Drive, Unit 2602,Aventura, Florida 33180;
(6) 21055 Yacht Club Drive, Unit 503, Aventura, Florida 33180;
(8) 4100 Salzedo Street, Unit 904, Coral Gables~ Florida 33146;
(16) 4100 SalzedG Street, Unit 909, Coral Gables, Florida 33146;
15
(18) 20 W. 53rd St, 47A, New York, New York 10019;
(19) 310 E. 53th Street, Apt 24C, New York, New York 10022;
(20), 330 E. 57th Street, Apt 9, New York, New York 10022;
--
(23) 60 Riverside Boulevard, PH 3702, New York, NY 10069; and
(24) 60 Riverside Boulevard, PH 3602, New York, NY 10069.
All pursuant to Title 18, United States Code, Sections 981(a)(l)(C) and 982(a)(l) and the
procedures set forth in Title 21, United States Code, Section 853, as incorporated by Title 18,
United States Code, Section 982(b)(l) and Title 28, United States Code, Section 2461(c).
1
RANDY A. HUMMEL SANDRA L. MOSER
ACTING UNITED STATES ATTORNEY ACTING CHIEF, FRAUD SECTION
ACTING UNDER AUTHORITY CONFERRED CRIMINAL DIVISION
BY 28 U.S.C. § 515
v~
Paul A. Hayden
Trial Attorneys
16
UNITED3-1
Case 9:18-cr-80160-WPD Document STATES DISTRICT
Entered COURT
on FLORIDA
FLSD Docket 08/17/2018 Page 17 of 18
SOUTHERN DISTRICT OF
UNITED STATES OF AMERICA CASE NO.

v.
RAUL GORRIN BELISARIO CERTIFICATE OF TRIAL ATTORNEY*
Defendant.
Superseding Case Information:
Court Division: (select One) New Defendant(s) Yes No

Number of New Defendants
Miami _ _ Key West Total number of counts
FTL __x_ WPB FTP
I do hereby certify that:
'
1. I have carefully considered the allegations of the indictment, the number of defendants, the number
of probable witnesses and the legal complexities of the Indictment/Information attached hereto.
2. I am aware that the information supplied on this statement will be relied upon by the Judges of this
Court in setting their calendars and scheduling criminal trials under the mandate of the Speedy Trial
Act, Title 28 U.S.C. Section 3161.
3. Interpreter: (Yes or No) YES
List language and/or dialect SPANISH
4. This case will take 14 days for the parties to try.
5. Please check appropriate category and type of offense listed below:
(Check only one) (Check only one)
I 0 to 5 days Petty
II 6 to 10 days Minor
III 11 to 20 days x Misdem.
IV 21 to 60 days Felony x
v 61 days and over
6. Has this case been previously filed in this District Court? (Yes or No) NO
If yes:
Judge: Case No.
(Attach copy of dispositive order)
Has a complaint been filed in this matter? (Yes or No) NO ,
If yes:
Magistrate Case No.
Related Miscellaneous numbers:
Defendant(s) in federal custody as of
Defendant(s) in state custody as of
Rule 20 from the District of
Is this a potential death penalty case? (Yes or No) NO
7. · Does this case originate from a matter pending in the Northern Region of the U.S. Attorney's Office
prior to October 14, 2003? Yes No X
*Penalty Sheet(s) attached REV 5/3/17


SOUTHERN DISTRICT OF FLORIDA
PENALTY SHEET
Defendant's Name: RAUL GORRIN BELISARIO
Count#l:
Title 18 United States Code 371
*Max. Penalty: Five (5) years' imprisonment
Counts #2:
Title 18, United States Code, 1956(h)
*Max. Penalty: Twenty (20) years' imprisonment as to each count
Count #3-11:
Title 18, United States ~ode, 1956(a)(2)(A)
*Max. Penalty: Twenty (20) years' imprisonment
*Refers only to possible term of incarceration, does not in dude possible fines, restitution,
special assessments, parole terms, or forfeitures that may be applicable.

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Case 9:18-cr-80160-WPD Document 3 Entered on FLSD Docket 08/17/2018 Page 1 of 18

UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA,

The Grand Jury charges that:

. At all times relevant to this Indictment, unless otherwise specified:

RELEVANT STATUTORY BACKGROUND

RELEVANT ENTITIES AND INDIVIDUALS

2. Defendant, RAUL GORRIN BELISARIO, was a citizen and national of

maintained a residence in Coral Gables, Florida.

3. "Company 1" was a company incorporated and registered in Panama, and is

beneficially controlled by defendant, RAUL GORRIN BELISARIO.

4. "Company 2" was a company incorporated and registered in Panama, and is

beneficially controlled by defendant, RAUL GORRIN BELISARIO.

beneficially controlled by defendant, RAUL GORRIN BELISARIO.

Sections 78dd-2 (h)(2)(A) and 78dd-3(f)(2)(A).

in acquiring the right to conduct such exchange transactions.

11. · In or around.2010, RAUL GORRIN BELISARIO partnered with Foreign Bank

proceeds of this and other schemes.

Official I and in furtherance of the scheme. .

· Foreign Official 2 to permit RAUL GORRIN BELISARIO to conduct foreign. currency

right to conduct such exchange transactions.

16. From in or around 2011 through m or around 2013, RAUL GORRIN

17. In exchange for Foreign Official 1 introducing RAUL GORRIN BELISARIO to

his scheme with Foreign Official 2 and Co-Conspirator 1.

2 and Co-Conspirator l's benefit.

21. RAUL GORRIN BELISARIO's employees tracked these expense payments

r~ferenced in paragraph 20 on spreadsheets and emailed updated spreadsheets to RAUL GORRIN

RAUL GORRIN BELISARIO,

against the United States, to wit:

and a means and instrumentality of interstate commerce in furtherance of an offer, payment,

instrumentality, in order to assist RAUL GORRIN BELISARIO in obtaining and retaining

violation of Title 15, United States Code, Section 78dd-2.

PURPOSE OF THE CONSPIRACY

co-conspirators by making and concealing corrupt payments to foreign officials in Venezuela in

MANNER AND MEANS OF THE CONSPIRACY

a. RAUL GORRIN BELISARIO, together with others, while in the

payments to foreign government officials in Venezuela to secure their assistance in awarding

contracts to RAUL GORRIN BELISARIO.

b. RAUL GORRIN BELISARIO, together with others, while in the

in Venezuela, to secure their assistance in awarding business to RAUL GORRIN BELISARIO.

c. RAUL GORRIN BELISARIO, together with others, while in the

by which the bribe payments were to be paid.

d. RAUL GORRIN BELISARIO, together with others, while in the

in Venezuela to conceal the bribe payments.

e. RAUL GORRIN BELISARIO, together with others, while in the

for the officials' assistance in awarding business to RAUL GORRIN BELISARIO.

District of Florida and elsewhere:

(1) In or around 2010, RAUL GORRIN BELISARIO, Foreign Bank Official,

money and paying bribes to Venezuelan officials.

(2) In or around 2012, RAUL GORRIN BELESARIO met with Foreign

Official 1 in the Southern District of Florida to discuss the payment of bribes.

that the "contact person is [Foreign Official 2]."

(4) On or about October 25, 2012, RAUL GORRIN BELISARIO sent an

(5) On or about October 29, 2012, RAUL GORRIN BELISARIO caused a

company's (referenced in paragraph 25 (4)) account in the Southern District of Florida.

Switzerland to a yacht company's account in the Southern District of Florida.

(7) On or about December 11, 2012, Foreign Official 1 e.mailed to RAUL

instructions for making the payment.