FinCEN advisory on Venezuela contemplates several TBML typologies

The US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued an advisory this week to alert banks and businesses about transactions with Venezuela related to corruption.

Suspicious transactions may be found in a variety of trade-based money laundering (TBML) schemes, according to FinCEN.

Special warning

The advisory alerts banks to look out for “financial red flags” and advises that they should report “suspicious activity that may be indicative of corruption.”

Also included is a special warning for exporting businesses in South Florida that specialise in selling to Venezuela. FinCEN believes they are “particularly vulnerable to TBML schemes.”

Shell companies

Other suspicious transactions may involve Venezuelan government contracts involving shell corporations, general “trading companies” or companies without a clearly defined business purpose.

Transactions involving Venezuelan government contracts may be regarded as suspicious if they contemplate companies that operate in an unrelated line of business, for example if payments for construction projects are directed to textile merchants.


Banks should watch for invoices involving Venezuelan government contracts that include charges at substantially higher prices than market rates or appear short of normally declared details, such as valuations for goods and services.

Other red flags include real estate deals in South Florida and Houston involving current or former Venezuelan government officials that are not commensurate with their official salaries.

FinCEN’s 20 September 2017 Advisory on Widespread Public Corruption in Venezuela can be found here.

Categories: Trade Based Financial crimes News

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