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UNITED STATESD IS-I'IUCT COURTIklr tlltl
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Soulllcrn Dislrict o1- 'Ikxas
Ullited Slates of A Inerica
&e.Abraham Jose Shiera-Bastidas Case No, 4:15-cr-654
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. j j - ' ' J - I j j j j 4 - j g j' vL''j'n.iz.! I l jul'î I - l . >Yh
2--1 person is mvaiting trial in another Federal or State Court, givename of coud
Q this person/proceeding transferred from anotber district per (circleone) FRCrP 1û, 21 of 4Q. Show Distrid
this ts a renrosecution of clhargt'sprevlously dismissed w'hlch wereùismissed Dn motion of:
C'I U.S. Att'y Z DefeYe
SHDWK CKET NO.
IS NOT IN CUSTODY
1) C1 Hag n0t been arresteö, pending outcome thl: prtxeLdingif not detained qive date any priœsblmmon: $!3$ served on above charoe:
2) (-..1 Is a Fuçitive
3) L).) Is on Ball or Relcase frcm ishqjv District O ', uslle a-
k, taly jivi'f !-1 -Is :N ctls-roD: .---- -.-
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4) FJ on thls chafge - , -.. ' . .) E..-t Fea I (-.J sute5) ( 7 oc armther convictinn6) L..! Awaiting trial on othef charges
lf answer (o (6) is ''Yes'', show name of Instltution
L. this prosecution relates to pendingcase involving this same defendant
lq7 prior proceedlngs or appearancels)before U.S. Maçistrale Judge regardingthis defendant Were recorded Smder
MAG. JUX EC-ASE N0.
L-J YesHas detalnerbeen filed? r.-j sc
DATE OF >,ARREA
lf %'Ye:''
j j yi uxyv e d a t e
Place orffeose Sotllhcrn District of- l-exnsc
7- ) pottyr--,...-1 l . ! i c o r'--iw hlikemeanor
Q? Felony
Or . . . lf àrrcstlhg Aqenp ?.j Waf r'anl wcf e qct Federal
DATE TM NSFERREDTO U.S. CUA ODY
This repoft amends previntls A0257 submitted
OFFENSE CHARGED - U.S.C. CU ATION -A ATLITORY MAXIMUM PENALTRES * ADDm ONAL INFORMATION OR COMMENTS
(.- l . l : (7 o n s p i r ac) I l 8 t .' . S . (- . j 3 7 I )
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N O T 1 C E O F 1 : O R 1 7 I:- I 1 ' t J I't 1! I 2 X U . S . C . j 2 4 6 I ( c ) ; 1 8 U - S . C . j 9 S l ( :1 1 l l ) 4 t* ) lN ( ) ' l - l f - l ê- () l : I ê O Ik f-. E I -1- U 11 E ! l 8 t .! . S . C . j k) 8 2 ( a ) ( I ) 1
Case 1:15-mj-03604-EGT Document 1 Entered on FLSD Docket 12/21/2015 Page 2 of 43
*
Case 4:15-cr-00654 *SEALED* Document 6 Filed in TXSD on 12/10/15 Page 1 cf 1Unlted States astlict CoudSeuma > Md d T@xxO ITED STATES DISTMW COURT
SOUTHERN DISR CTOF TEXAS
HOUSTON DIVISION
UNIR D STATES OF AMERICA
ABRAHAM JOSE SHIERA-BASTIDAS
ENTEREDe e 11, 2015
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. <. Clefk/'.. .x v%N
N.oa s QcRlMINAtNo: -. - %
SEALED
! r, p,p 6 q 4.' . .
15 C0 6 54
ORDER FOR ISSUANCE OF BENCH WARFANT
A CM Mm AL INDICTMENT
below.
It is ORDERKD that a warrant be issued for the arrest cf said defcndr t. Upon arrest and
appearance, ajudicial determination sbsll be made as to dettntion or relen- on conditions. n e
United State: Govemmtnt recommends to the Court the following:
has been returned against the defendant lixed
Defendant
ABM HAM JOSE SHIERA-BASTIDAS
- -
- u praw sjox
0 RELEASED 0N CONDITIONS
Q APPEAM NCE BOND IN THEAMON OF: $
SIONED at Houston, Texas. on . .- -..- -. .. /-Y.,.... , 2,0 .. .-.... .
UNITED STATES MAGISTRM E JUDG
Case 1:15-mj-03604-EGT Document 1 Entered on FLSD Docket 12/21/2015 Page 3 of 43
@1M?Dtx Dlslld'C2mt- = Fgtudsd T*
2EC 1 9 2215
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UNITED STATES DISTRICT COURTSOW HERN DISTRICT OF TEXAS
HOUSTON DIW SION <Mw .
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M.
ROBERTO ENRIQUE Rm CON.FERNANDEAABRAHAM JOSE SHV RA.
BM TD AS
CQIM INAL NO.'-'W ,
: 5 21 6 54
INDICTM NT
Tlœ GRAND JURY CHARGES:
COUNT ONE
(Conspiiacy - 18 U.S.C. # 371)
htrûduction
At all relevant times, unless otherwise specified:
1 . n e Foreir Conupt Pmctices Act of 1977 (tTCPA''), as amended,
Title 15, United States Code, Sections 78dd-1, et seq., was enacted by Conpess for
the pupose ot among other thinp, making it unlawful to act co= ptly in
furtherance of an oFer, promise, authorization, or payment of money or anything
of value, directly or indirectly, to a foreir official for the purpose of obtaining or
retaining business for, or directing business to, any person.
Petroleos de Venezuela S.A. (tTDVSA'').was the Venezuelan state-
ou ed and state-controlled oil company. PDVSA and its subsidiaries and afsliates
Case 1:15-mj-03604-EGT Document 1 Entered on FLSD Docket 12/21/2015 Page 4 of 43
were responsible for the exploration, production, refninp transportation, and trade
in energy resources in Venezuela and provided funding for other om rations of the
Venezuelan govemment. PDVSA Services, hc. was the U.s.-based aK liate of
PDVSA located in Houston, Texu, that, at vmious times, wc responsible for
intem ational purchasing on behalf of PDVSA. Bariven S.A wa the PDVSA
procurement subsidiary responsible for equipment purchases. PDVSA and its
wholly owned subsidiaries, including PDVSA Services, Inc. and Bariven S.A.,
(hereinoer collectively referred to as tTDVSA'') were ''instrumentalities'' of the
Venezuelan govemment as that term is used in the FCPA Title 15, United States
Code, Section 78dd-2(h)(2)(A). PDVSA oKcers and employees were çtfortign
omcials'' as that term is USH in the FCPA Title 15, United States Code, Sections
78dd-2(h)(2)(A) and 78dd-3(f)(2)(A).
PDVSA awarded contrac? for tnergy services and equipment in a
number of ways, including tkough a competitive bidding process. One such
competitive bidding process began with a PDVSA pumhasing analyst % sembling a
bidding panel, which identified those companies that would be invited to submit
bids in connection for a particular project. PDVSA would then issue a request for
quotation to the companies included on the bidding panel and those companies
would in tum submit formal bids, from which a winner would bt selected.
Case 1:15-mj-03604-EGT Document 1 Entered on FLSD Docket 12/21/2015 Page 5 of 43
PDVSA also awarded sole source contracts, which were not subject to a
competitive bidding process.
n e Defendants and Thqir Coccon,pirators
4. Defendant ROBERTO ENRIQUE Y CON FERNANDEZ
(ç%m CON'') was a U.S. lawful permanent resident and a resident of Texas, and
controlled, together with others, a number of closely held companies, including
several U.S. companies, many of which were based in the Southern District of
Texas, that Rm CON used to secure contracts with PDVSA . Rm CON was thus a
rtdomestic concem '' and an om cer, director, employee, agenj and shareholder of a
'tdomestic concem'' as those teru are used in the FCPA Title l5, United States
Code, Section 78dd-2(h)(1).
Defendant ABRAHAM JOSE SHVRA BASTD AS C%HVRA''I
was a Venezuelan national who resided in Floridw and controlled, together with
others, a numbe: of closely held oorppanies, including seveml U.S. companies, that
SRTERA used to secure contracts with PDVSX SHIERA was thus a çfdomestic
conoem'' and an offcer, director, employee, agent, and shareholder o a Rdomestlc
concem'' as those terms are tlsed in the FCPA Title l 5, United States Code,
Section 78dd-2(h)(1). Rm CON and SHIRRA worked together on a number of
PDVSA contracts and contract bids.
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6. çtRincon Company 1,'' a company whose identity is known to the
Grand Jury, was organized under the la< of Ttxas and headquartered in the
Southem District of Tex%. m ncon Company 1 was thus a'tdomestic concem'' as
that term is used in the FCPA Mtle 15, United States Code, Section 78dd-2(h)(1).
Rincon Company l - controlled by RG CON and used by RW CON to secure
contracts with PDVSA.
7. 'Rincon Company 2,1' a company whose identity is knom l to the
Grand Jury, was organized under the lax of Tex% and headquarterd in the
Southem Dislrict of Ttxa. Rincon Company 2 was thus a ''domestic concem'' as
that term is used in the FCPA Title 15, United States Code, Section 78dd-2(h)(1).
Rincon Company 2 was controlled by Rm CON and used by Rm CON to secure
contrads with PDVSA.
8. tçRincon Company 3,1' a company whose identity is known to the
Grand Jury, was organized under the la< of Fiorida and headquadered in Florida.
Rincon Company 3 was thus a t<domestic concem'' as that term is used in the
FCPA Title 15, United States Code, Section 78dd-2(h)(1). Rincon Company 3
was controlled by RD CON and used by RINCON to secure contracts with
PDVSA.
4
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9. 'fRincon Company 4,:1 a company whose identity is known to the
Grand Jury, was controlled by RINCON an# used by Rm CON to secure contracts
with PDVSA
10. %'Shiera Company 1,3' a company whose identity is hmwn to the
Grand Jury, was organized undet tht laM of Florida and headquartered in Florida-
Shiera Company 1 was thus a ttdomestic concem'' as that term is USGI in the
FCPA Title 15, Unittd States Codt, Section 72dd-2(h)(1).Shitra Company 1 was
controlled by SHV RA and used by SHTRM to secure contrac? with PDVSA-
fçshitra Company 2,': a company wlwse identity is known to the
Grand Jury, w% organized under the la< of Florida and headquadered in Floridm
Shiera Company 2 was thus a Qtdomestic concem'' as that term is used in the
FCPA Title l5, United States Code, Section 7:dd-2(h)(1). Shiera Company 2 was
controlled by SHV RA and use,d by SHR RA to secure contracts with PDVSA.
l2. çsshiera Company 3,'1 a company whose identity is known to the
Grand Jury, was organized undtr the la< of Florida and headquu ered in Floridm
Shiera Company 3 was thus a çtdomestic concem'' as that term is used in the
FCPA Title 15, United States Code, Section 78dd-2(h)(1). Shiem Company 3 was
controlled by SHIEM and used by SHIEM to secure contracts with PDVSA .
Case 1:15-mj-03604-EGT Document 1 Entered on FLSD Docket 12/21/2015 Page 8 of 43
13. Ssshiera Company 4,'3 a company whose identity is known to the
Grand Jury, was controlled by SHV RA and used by SHV RA to secure contracts
with PDVSA.
14. t<shiera Compaay 5,'' a compc y whose identity is knou to the
Grand Jury, was controlled by SHV M and USM by SHR RA to secure contracts
with PDVSA-
'Cshiera Company 6,:' a company whose ideitity is u own tè the
Grand Jury, whs controlled by SHIRA and used by SHVRA to secure contracts
with PDVSA.
16. ççM sociate 1,'' an individual whose identity is known to the Gtand
Jury, was a U.S. lawful permanent resident and a resident of Texas and a relative
of RINCON, who controlltd, along with Rm CON, several of the U.S. companits
controlled by RG CON. Associate 1 was thus a fçdomestic concem'' and an
o/ cer, director, employee, agent, and shareholder of a ttdomestic concem'' as
those terms are used in the FCPA Title l5, United States Code, Section 78dd-
2(h)(1).
17. çtM sociate 2,': an individual whose identity is knomz to the Grand
Jury, was a Venezuelan national who maintained a residence in Texu, and was
employed by, or worked as an independent contmctor for, SHY RA and assisted
both RD CON and SHIERA in their business operations, including by assisting
Case 1:15-mj-03604-EGT Document 1 Entered on FLSD Docket 12/21/2015 Page 9 of 43
RD CON and SHV RA and their companies, including their U.s.-based
companies, secure contracts with PDVSA- 'IYus, M sociate 2 was an agent Qf a
''domestic conctm'' as that term is ustd in the FCPN Title l5, United States Code,
Section 78dd-2(h)(1).
The Foreien Om cials
18. t'Oïcial &'' ml individllnl whose identity is known io the Grand Jury,
was at aIl relevant times employed by PDVSA including as a buyer at PDVSA and
a supervisor of other PDVSA buyers. Oïcial A's job responsibilities included
assir ing bidding pantls to PDVSA buyers, including Official C and Oï cial D,
who would then be responsible for selecting cnmpanies for the bidding panels,
which allowed those companies to submit bids on ipdividual PDVSA projects.
19. 'D m cial B,'' an individual whose identity is known to the Grand Jury,
w% at all relevant times employed by PDVSN including as a purchasing analyst
for PDVSA. Oïcial B's job responsibilities included selecting companits for
bidding panels, which allowed those compu ies to submh bids on indiKdual
'
prol ects.
20. f'Oï cial C,'' an individual whose identity is known to the Cx'and Jury,
was at aIl relevant times employed by PDVSA including as a purchasing managtr
and superintendent of purchasing at PDVSA. O/ cial C's job responsibilities
included selecting companies for bidding panels, which allowed those companies
Case 1:15-mj-03604-EGT Document 1 Entered on FLSD Docket 12/21/2015 Page 10 of 43
to submit bids on individual PDVSA projems, Md selecting which companies
would win the economic portion of tht bid process.
21. tsoï cial D,'' an individual whose identity is known to the Grgnd Jury,
wu at all rtlevant times employed by PDVSA including as a buyer for PDVSA
OE cial D. 's job ruponsibilities included selecting companies for bidding panels,
which allowed those companies to submit bids on individual PDVSA projects.
22. fsofficial E,'' an individual whose identity is known to the Grand Jury,
was at alI relevant times employed by PDVSA including as a purchasing manager
at PDVSA- Oëcial E's job responsibilities included selecting companies for
bidding panels, which allowed those companies to submit bids on individui
PDVSA projects.
23. Official h, Om dal B, Official C, Ofscial D, and OK cial E were each
a tsforeir omcial'' as that term is used in the FCPA Title 15, United States Cpde,
Sections 78dd-2(h)(2)(A) and 78dd-3(9(2)(A).
8
Case 1:15-mj-03604-EGT Document 1 Entered on FLSD Docket 12/21/2015 Page 11 of 43
The Conspiracy
24. Beginning in at le>qt 2009 and continuing throul at lexqt 2014, in the
Southem District of Tex%, and elsewhere, the defendants,
ROBERTO ENRIQUE RW CON FERNANDEZand
ABRAHAM JOSE SHV RA BASTD AS
did will'fully and knowingly conspire, confederate, and apee with each other and
others known and unknown to the Grand Jury to commit o/enses against the
United States, that is:
a. to willfully make use of the mails and means and instrumentalities of
inteotate commerce conuptly in furtherance of an offer, payment,
proe se to pay, and authorization of the payment of any money, ofer,
gii, promise to give, and authorization of the giving of anything of value
to a foreir official and to a person, while knowing that all and a portion
of such monty and thing of value would be and had been offered, given,
and promised to a foreir oKcial, for purposes of: (i) influencing acts
and decisions of such foreir offkial in his o/cial capacity; (ii) inducing
such foreir oK cial to do and omit to do acts ia violation of the lawful
duty of such oKcial; (iii) securing an improper advantage; and (iv)
inducing such forei> oftk ial to use his iniuence with a foreir
9
Case 1:15-mj-03604-EGT Document 1 Entered on FLSD Docket 12/21/2015 Page 12 of 43
govtm ment and agencies and instrumentalitio thereof to affect and
influence acts and decisions of such govem ment and agencies and
instrumeatalities, in order to usist Rm CON, SHV RA. and their U.S.
companies in obtaining and retining businœs for and with, and dirtcting
business to, Rm CON, SHV RA, their companies, and others, in
violation of the Foreir Corrupt Practicts Act, Mtle l5, United States
Code, Section 78dd-2(a);
b. while in the tenitory of the United States, willfully and com zptly to make
use of the mails and means and instrumtntalities of interstate convnerce
and to do any other act in furtherance of an ofrer, payment, promise to
pay, artd authorization of the payment of any money, oFer, gih, promist
to give, and authorization of the giving of anything of value to a foreir
o/ cial and to a person, while knowing that a1I and a portion of such
money and thing of value would be and had been oFered, given, and
promised to a foreir omcial. for pumoses of: (i) infuencing acts and
decisions of such fofeir oflicial in his or her official capacity; (ii)
inducing such foreir official to do and omit to do acts in violation of the
lawful duty of such official; (iii) securing an improper advantage; and
(iv) inducing such foreir ofcial to use his or her influence with a
foreir govem ment and agencies and instrumentalities thereof to affect
10
Case 1:15-mj-03604-EGT Document 1 Entered on FLSD Docket 12/21/2015 Page 13 of 43
and influence acts K d decisions of such govem ment and agencies and
instmmentalities, in order to assist Rm CON, SHV RA, and their U.S.
companies in obtaining and retaining business for and witk and directing
business to, Rm CON, SHIERA, their compu ies, and others, in
violation of Mtle 15, United States Code, Section 78dd-3(a); and
c. to devise and intend to devise a scheme or artifice to defraud PDVSA and
energy companies that could have performed service.s for PDVSA and
for obtaining money and propely from PDVSA and energy companies
that could have performed services for PDVSA by means of materially
false and H udulent pretenses, representations, and proY ses, and to
transmit and cause to be tmnsmitted, by me-qns of wire communication in
interstate and foreir commtrct, writinp, sir s, sir als, pictures, and
sounds for the purpose of executing such scheme and artisce in violation
of Title 18, United States Code, Section 1343.
Purpose of the Ccnspiracv
25. n epupose of the conspîracy wastài-luxcox, SHGRA, and their
oo-conspirators, to enrich theM elves by obtaining and retaining lucrative energy
oontracts witb PDVSA through corrupt and fmudulent means, Ycluding by paying
bribes to PDVSA officials.
11
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M anner aRd M eans of th: Conspiracv
26. n e manner and means by which Rm CON and SHG RA and thtir
co-conspirators sought to accomplish the purpose of the conspiracy inoluded,
among other thinp, the following, while in the Southem District of Texas and
elsewhere:
27. Rm CON and SHW RA, together with othtrs, discussed how they
would obtain and retain contmcts with PDVSA by providing thino of value to
PDVSA officials.
28. RD CON and SHY M , together with others, paid bribes to PDVSA
oï cials through the use of interstate and fofeir wires in order to influence acts
and decisions of the PDVSA offidals in their oï cial capacities and to induce the
PDVSA oE cials to do and omit to do certain acts, including, but not limited to:
a. usisting Rm CON'S and SHIRRA'S companies in winning PDVSA
contm cts;
b. providing Rm CON and SHW M with inside information conceming
85. Pm paphs 1 throul 23 and 25 tkough 84 are realleged and
incomorated by reference as though fully set forth herein.
26. On or about the dates set fo% below, in the Southem District of
Texas and elpewhere, the defendant,
ROBERTO ENRIQUE Rm CON FERNANDEZ,
being a domtstic concem and an offcer, director, employee, agent, and
shareholder of a domestic concem, and by aiding and abetting a domestic concern
,
did willfully use and catlse to be used the mails and means and instrumentalities of
interstate commerce corruptly in furtherlnce of an ofer, payment, promise to pay,
and authorization of the payment of money, oFer, gih, promise to give, and
authoriymfion of the giving of anything of value to a foreir official, and to a
person, while knowing that all and a poltion of such money and thing of value
would be and had been offered, given, and promised to a foreir official, for
purposes of (i) iniuencing acts and decisions of such forei> o/cial in his or her
oKcial capaciy (ii) inducing such foreir oKcial to do and omit to do acts in
violation of the lawful duty of such official; (iii) securing an improper advantage;
and (iv) inducing such foreir official to use his or her influence with a foreir
govemment and agencies and instrumentalities thereof to affect and influence acts
26
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and decisions of such govemment and agencies and instrumentalitiu, in order to
usist RmCON, SHVRA, and their U.S. companies in obtaintng and retaining
business for and with, and directing business to, W NCON, SHTRIG , their
companies, and othen, as follox ;
COUNT DATE BQm E PAYM ENT
Two September 23, 2010 T100,000 wire trnnqfer from M ncon Company
4's bnnk account in Florida to Oë cial C's bnnkaccount in the Southem District of Texas.
'Ihree April 12, 201 1 $200,000 check from RINCON'S bank account
in the Southem District of Texc to a bankaccount in Florida in the name of a oompanyox ed b an csociate of Oï cial C.
Four M ay 8, 2012 $150,000 wire transfer from Rincon Company
2's bank acoount in the Southem District of
Texas to a bank account in New York in thename of a com an co-ou ed b Offkial C.
Fivt December 21, 2012 $150,000 wife transfer from Rincon Company2's bank account in the Southem District ofTexu to a bnnk accotmt in Florida in the name
of a com an cmo- ted b Ofûcial C.
All in violation of Title 15, United States Code, Section 78dd-2, and Title
18, Unittd Statu Code, Section 2.
27
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102. ParaFaphs 1 tlvough 23, 25 throul 84, and 91 through 99 are
realleged and incorporated by reference as thoul fully set forth herein.
103. On or about the dates set forth below, in the Southem District of
Texu and elsewhere, the defendants,
ROBERTO ENRIQUE RW CON FERNANDEZand
ABRAHAM JOSE SHœ RA BASTD AS,
did knowingly engage, and aid, abet, and cause others to engage, and attempt to
engage in the following monetary transactions, by, through, and to a financial
institution, a/ecting interstate and foreir commerce, to wit: the deposit,
withdrawal, transfer and exchange of United States currency, funds and x netary
instruments, in criminally derived property of a value peater than $10,000, such
property having been derived from specitled unlawful activity, that is, a felony
violation of the FCPA Title 15, United States Code, Sections 78dd-2 and 78dd-3.
and wire fraud, Title 18, United States Code, Section 1343, as follows:
COUNT DATE M ONETARY TRANSACTIONFiheen M ay 23, 201 1 9
,962,000 wire tx sfer from RinconCompany 1's bank account in the SouthemDistrict of Texa to a bank account in
Switzzrland in the name of CompanyAccountholder A.
36
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COUNT DATE M ONETARY TRANSACTIONSixtetn M ay 24, 201 1 $15,000,000 wire transfer from Rincon
Company 1's bank account in the Southem
Disi ct of Texas to a bnnk account inSwitzerland in the name of Company
Accountholder B.
Seventeen June l7, 2011 $2,422,005 wire transfer from RinconCompany 1's bank account in the SouthemDistrict of 'texas to a bnnk account inSwitzerlc d in the name of CompanyAcx untholder A.
Eighteen January 17, 2012 $3,097,527 wire transfer from ShieraCompr y 2's bank account in Florida to abank account in Switzerland in the name of
Com an Accountholder C.
A1l in violation of Title 1 8, United States Code, Sections 1957 and 2.
37
Case 1:15-mj-03604-EGT Document 1 Entered on FLSD Docket 12/21/2015 Page 40 of 43
NOTICE 01 C'RN m AL FORFEITURE
(28 U.S.C. j M61(c); 18 U.S.C. j 981(a)(1)(C))
104. Pursuant to M tle 28, United States Code, Section 2461(c) and Title
18, United States Code, Section 98 1(a)(1)(C), the United States gives notice to the
defendants,
ROBERTO EY QUE RW CON FERNANDEZand
ABRAHAM JOSE SHV RA BASTD AS,
that in the event of conviction of any of tile oFenses charged in Counts 1 through 10
of this Indictment, the United States intends to seek forfeiture of all property, real or
personal, which constitutes or is derived from proceeds traceable to such Qffensts.
NOTICE OF FORFEITURE
(18 U.S.C. j 982(a)(1))
105. Pursuant to Title l 8, United Statu Code, Section 982(a)(1), the
United States gives notice to the defendants,
ROBERTO ENW QW Y CON FERNANDEZand
ABR-
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that upon conviction of any of the oFenses charged in Counts 1 1 through 18 of this
hdictment, >ll propedy, real or personal, involved in money laundering offenses or
M ceable to such properiy, is subject to forfeimre.
38
Case 1:15-mj-03604-EGT Document 1 Entered on FLSD Docket 12/21/2015 Page 41 of 43
Propertv Subivct to Ferfeiture
106. Defendants are notified that the property subject to forfeiture includes,
but is not limited to, the following property:
a. Bank Account of Company Accountholder A at Credit Suisse in
Swita rland, with an account number ending in 6032;
b. Bank Account of Company Accountholder B at Credit Suisse in
Switzzrlc d, with m1 account number ending in 9852;
c. Bank Account of Company Accountholder C at Credit Suisse in
Swita rland, with an account number ending in 2004; and
d. Sunseeker M anhattan 73 M otor Yacht, Serial Number GB-XSK 0581 1
J213, co-oM ed by SHV RA.
M oney Judzment
107. Defendants are notified that upon conviction, a moneyjudgment may
be imposed equal to the total value of the property subject to forfeiture, for which