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Tomás Niembro Concha, the former CEO of Puerto Rico-based Nodus International Bank, was sentenced to 112 months in prison after being convicted in a scheme that fraudulently obtained at least $24.9 million from the bank and involved the evasion of US sanctions against Venezuela. The DOJ said Niembro abused his senior position at the bank for personal enrichment while conspiring to circumvent restrictions applying to a sanctioned individual. He was also ordered to forfeit more than $16.9 million representing proceeds derived from the wire-fraud conspiracy. The case is notable for combining sanctions evasion with misconduct by a senior executive inside a regulated financial institution.

Javier Aguilar, a former oil trader for Vitol, was sentenced to 48 months in prison for his role in two schemes to bribe government officials in Ecuador and Mexico. Prosecutors said Aguilar conspired to pay more than $1 million in bribes connected with over $500 million in oil and gas contracts, including payments involving officials associated with Ecuador’s state-owned oil company and PEMEX Procurement International, an affiliate of Mexico’s state-owned oil company. Aguilar was convicted of FCPA and money-laundering offences relating to the Ecuador scheme and pleaded guilty to charges arising from the related Mexican scheme. He was also ordered to forfeit $7.13 million and pay a $100,000 fine.

Javier Aguilar was sentenced to 48 months in prison for interconnected schemes involving officials in Ecuador and Mexico. He had previously been convicted of FCPA and money laundering offences relating to Ecuador and pleaded guilty over a related scheme involving officials at an affiliate of Mexican state-owned oil company PEMEX. Prosecutors said more than $1 million in bribes were paid to obtain business worth over $500 million, while Aguilar forfeited more than $7.1 million in laundered funds. This is a particularly useful example of the continuing intersection between foreign bribery enforcement and AML.

The nationwide alcohol distributor entered into a non-prosecution agreement after employees and executives funded improper payments and benefits intended to influence retailers’ purchasing and product-placement decisions. The company acknowledged that third-party vendors and false invoices were used to conceal the payments. Although this is a domestic commercial bribery case rather than an FCPA matter, it provides a useful compliance example of the risks created by third-party intermediaries, inadequate payment controls and false books and records.