Venezuela's Laundered Billions

In 2017, a money launderer sat in a Madrid office and explained his business model into a hidden recording device. Hugo Gois was describing a professional service: how to move hundreds of millions of dollars in stolen Venezuelan oil money through European financial institutions without triggering a single compliance alert.

"We invest a lot in research so that we can carry out operations without the machines detecting it," Gois explained to an associate he believed was a potential client. The machines he referenced were the KYC and anti-money laundering systems that banks rely on to screen transactions. His method exploited the gaps between jurisdictions where compliance responsibility becomes deliberately unclear. The scheme Gois helped orchestrate ultimately moved $1.2 billion in funds stolen from Venezuela's state oil company, PDVSA. By the time U.S. authorities dismantled the network in their "Operation Money Flight" investigation, Venezuela's oil wealth had been converted into Miami real estate, Spanish horse farms, and Swiss bank accounts.

The Visible Surface: Legitimate Financial Services

Examined individually, each participant appeared unremarkable. The voices in the recording belonged to Hugo Gois, a Portuguese financial consultant based in Caracas; Ralph Steinmann, a Swiss asset manager with access to European institutions; and José Vicente Amparan, a Venezuelan lawyer holding power of attorney for investment accounts. A licensed financial services firm in Cyprus and UK financial institutions are also mentioned.

Standard compliance protocols evaluated each node independently and triggered no alerts. Gois had no criminal record. Steinmann operated through established banking channels. The Cypriot entity held proper licensing. Transactions fell within normal parameters for wealthy Latin American clients diversifying into European markets.

The Hidden Reality: The Architecture of Invisibility

The secret recording revealed that these weren't separate actors conducting independent transactions. Instead, they formed a deliberate network engineered to exploit the fact that compliance systems evaluate entities in isolation.

Gois explained how the network positioned each node to create jurisdictional ambiguity. The Cypriot entity would be a bridge to open accounts at UK brokerages, which in turn would trust that compliance was done in Cyprus. Where UK firms saw a licensed Cypriot broker, Cyprus regulators saw routine outbound investment activity. Without a view of the full network, neither connected the dots to PDVSA corruption.

This architectural approach extended across the entire operation. Steinmann provided European banking access and designed tax structures where even to the banks the ultimate owner was not revealed. Amparan held power of attorney, creating legal distance between stolen funds and their ultimate beneficiaries. Shell companies in Panama added layers. Trusts in multiple jurisdictions obscured beneficial ownership. Each component appeared legitimate when examined individually. The criminality existed in the connections between them.

U.S. authorities ultimately mapped this network through Operation Money Flight, which revealed how $1.2 billion was embezzled from PDVSA through bribery schemes involving senior officials. Abraham Edgardo Ortega, PDVSA's executive director of financial planning, accepted bribes to facilitate the theft. According to U.S. court documents, Gois served as a financial asset manager for multiple Venezuelan officials, working alongside Steinmann and Amparan to move the proceeds through European banking channels.

The scale of Venezuelan oil sector corruption extends far beyond this single network. The Atlantic Council estimated in 2020 that officials siphoned at least $28 billion from PDVSA between 2004 and 2020. FinCEN enforcement actions revealed that professional money laundering networks established hundreds of shell companies to process Venezuelan corruption proceeds through "false contracts, mischaracterized loans, over- and under-invoicing, and other trade-based money laundering schemes."

The Business Implication

The professional laundering network that moved PDVSA's stolen billions exposes a fundamental flaw in conventional due diligence: compliance systems evaluate entities individually, while sophisticated criminals operate as networks specifically designed to exploit that blind spot.

For financial institutions handling cross-border transactions, the implications are direct. When a Cyprus brokerage opens an account at a UK firm, standard KYC examines the Cypriot entity's licensing, documentation, and transaction history. It doesn't map whether that entity to other entities or individuals, in Cyprus or elsewhere.

Financial institutions face more than reputational damage. The U.S. Treasury's 2019 designation of PDVSA under Executive Order 13850 created sanctions exposure for any institution that facilitated transactions with the entity, even unknowingly. By 2019, U.S. prosecutors had charged 33 individuals in Venezuelan corruption cases, with 19 pleading guilty. The Venezuela Asset Recovery Initiative tracked $139 million in seized assets across multiple jurisdictions. While the sanctions architecture from the US is changing with regard to Venezuela, the BIS Affiliates rule will hold (later this year). No matter what the US says, many networks still include illicit actors.

Conclusion

The recording of Hugo Gois describing his laundering methodology was a business development meeting for network services already operating at scale. While he spoke in that Madrid office, PDVSA funds were actively moving through the European financial infrastructure he described, each node appearing legitimate in isolation, the criminality visible only in the connections between them.

The professionals who build these networks understand compliance systems intimately. They study how KYC evaluates entities individually. They research jurisdictional gaps where no single regulator sees the complete picture. They structure operations to fragment suspicious activity across multiple institutions, knowing that standard screening won't connect the dots.

Evidencity's Illicit Network Intelligence reveals exactly what entity-level screening misses: the professional networks where Hugo Gois provides research, Ralph Steinmann provides access, and José Vicente Amparan provides legal cover. These individuals don't appear on sanctions lists. Their companies hold proper licenses. The risk exists in the architecture connecting them.

Where conventional due diligence questions the legitimacy of an entity, network intelligence asks what network the entity enables. That difference determines whether you see $1.2 billion in stolen oil money as routine cross-border investment or as the illicit professional infrastructure it actually represents.

Thank you to OCCRP for your reporting on this topic.