The recent indictment of Venezuelan media executive Raul Gorrin Belisario provides valuable insights into sophisticated money laundering techniques exploiting institutional banking vulnerabilities
Key Money Laundering Methodologies Identified:
1. Initial Layering Structure:
• Used Hong Kong shell company (Eaton Global Services) for primary fund receipt
• Executed sham joint venture contracts to justify fund movements
• Employed internal transfers within same financial institution to minimize external transfer scrutiny
• Utilized parallel company structures in multiple jurisdictions (Hong Kong, Panama, Scotland, Marshall Islands)
2. Fund Flow Concealment:
• Split proceeds between multiple shell companies using false documentation
• Created tiered ownership structures with nominee directors
• Used internal bank transfers to avoid external banking system scrutiny
• Employed sham contracts to justify PEP-related transactions
3. Red Flags Identified:
• Complex ownership structures involving multiple jurisdictions
• High-value transactions justified by vague consulting agreements
• Frequent internal transfers between related entities
• Use of nominee directors from low-risk jurisdictions
• Involvement of politically exposed persons (PEPs)
• Large currency exchange transactions at preferential rates
4. Integration Methods:
• Luxury asset purchases (yachts, aircraft) through multilayered company structures
• Real estate investments in high-value markets
• Aircraft insurance payments through separate corporate entities
• Use of specialized financial managers and asset management firms
Key Takeaway for AML Professionals:
This case highlights the importance of enhanced due diligence on:
– Internal transfer patterns between related entities
– Transaction justification documentation
– Ultimate beneficial ownership verification
– PEP-related transaction monitoring
– Cross-border structure analysis