May 14th, 2026
In January 2026, the U.S. Department of Justice indicted Jorge Figueira, a Venezuelan national, for laundering nearly $1 billion using a variety of methods, including cash, crypto, Over-the-Counter (OTC) brokerages, and shell companies.
The risks crypto and shell companies present to money laundering are well known; however, the interesting area of this case is Figueira’s methods to bypass regulations and due diligence processes through his understanding of the variations in regulations across jurisdictions.
Before delving into the finer details, Figueira’s methodology was rather simple and followed the three stages of money laundering. Figueira first deposited cash from the proceeds of crime into bank accounts in Panama or Venezuela, hesitant to receive cash in the US due to the higher scrutiny he would face there compared with Venezuela or Panama. From there, the cash would be converted to crypto, specifically Tether (USDT), on the Tron blockchain, which offers lower transaction fees. The use of the Tron blockchain was particularly important during the layering stage, as Figueira’s network would then move the USDT through multiple crypto wallets, usually through four to nine transactions over a short period, before arriving in a ‘macro-wallet.’ From there, Figueira took his final step of converting the crypto back to fiat currency through OTC brokerages in both the US and the UK, which were then transferred to shell companies he operated before finally being wired to the final beneficiary.
Onboarding shell companies is subject to enhanced due diligence and requirements around the transparency of beneficial ownership under FATF’s Recommendation 24, as well as US legislation. However, Figueira stated he bypassed this by describing the shells as a credit company or a trade financing consulting company rather than a money transmitter, which would have attracted enhanced due diligence. Figueira also created websites to meet banks’ due diligence requirements and make the shells seem like legitimate businesses. This highlights the gaps in due diligence, especially based on the risk-based approach (RBA). Under the RBA, it may seem like financial institutions have done a reasonable amount of due diligence during onboarding, but this is when ongoing due diligence becomes crucial. A closer look at the financial activity of shell companies would have highlighted the high activity, with it being reported inflows and outflows over two years being approximately $2.8 billion. This should have raised red flags regardless of the nature of the business. Moreover, checks into expenses such as payroll should have highlighted the lack of business operations through these companies.
The use of USDT and the Tron blockchain is also an interesting case. USDT is a particularly important tool in money laundering, as it is pegged to the US dollar, and is therefore less volatile in pricing than its alternatives, such as Bitcoin and Ethereum. Moreover, with the Tron blockchain offering lower transaction fees, it makes it a vital source during the layering stage, as launderers would lose less value as they transfer through multiple wallets. As mentioned, the risks of crypto have always been well-known, but what the case highlights is the importance of blockchain analytics and Public-Private Partnerships (PPP). Through blockchain analytics, the FBI was able to trace a $50,000 transaction move through nine different transactions in 22 minutes, highlighting no legitimate business purpose for the speed and structure of the transactions. Furthermore, through blockchain analytics, it is possible to address the pseudonymity concern associated with cryptocurrency and the blockchain, as every transaction leaves a permanent and traceable record. This reinforces the role PPPs play as an operational necessity. Private organisations that offer blockchain analytics tools and training aid public investigators with the opportunity to strengthen blockchain analytics across jurisdictions to better prevent financial crime risks from blockchain.
One of the most important points from the case is Figueira’s knowledge of regulations across jurisdictions, which made it possible for Figueira to grow his laundering network. This highlights the growing need for international co-operation, one of FATF’s recommendations, but also the importance of FATF’s AML/CFT technical and effectiveness mutual evaluations to highlight high-risk countries, and display scrutiny with transfers to and from them. In the case of Figueira, the placement stage started in Venezuela or Panama, which is due to their cash-intensive economies, making the deposit of cash less risky as compared to the US or other jurisdictions, which have Currency Transaction Report (CTR) requirements, requiring financial institutions to report on cash transactions exceeding $10,000. Venezuela is on the FATF’s Grey List due to vulnerabilities found in its AML/CFT regulations. This highlights Venezuela’s weakness, which Figueira exploited, and highlights how the potential for uniform global AML regulations could have prevented the multiple jurisdiction exploitation Figueira utilised.
Do you think uniform global AML regulations would have prevented Figueira from growing his network?
Links:
Institute for Financial Integrity Assessment: https://finintegrity.org/professional-crypto-laundering/
Elliptic Case Study: https://www.elliptic.co/blog/us-case-reveals-billion-dollar-venezuelan-stablecoin-laundering-scheme
FATF Grey List: https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html
The AML Analyst 
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