Case 1:24-cr-20343-KMW Document 23 Entered on FLSD Docket 08/13/2024 Page 1 of 1

M IN UTE O RD ER Page5
M agistrate Judge Lauren F.Louis
AtkinsBuildingcourthouse-11thFloor Date:8/12/24 Time:2:00p.m.
Defendant:2)RogerAlejandropinateMartinez J#:29768-511 Case#: 24-20343-CR-W ILLIAMS
AUSA: Rob Emery/connorMullin Attorney: CurtisM iner/sandra M ozier(Temp)
violation: MoneyLaundering surr/ArrestDate:8/12/24 YOB:1975
Proceeding: InitialAppearance CJA A ppt:
Bond/PTD Held:f-'Yes C No Recommended Bond:
Bond Setat: Co-signed by:

U-
VIsurrenderund/ordonotobtainpassports/traveldocs Language: Spanish
ReporttoPTsasdirected/or x'saweek/monthby Disposition:
phone: xzsaweek/monthinperson . .
Random urine testing by pretrial
nr services
.
charges
Treatm ent asdeem ed necessary
NV Refrainfrom excessiveuseofalcohol Counselfilestemporarysppellrnre
Nr participateinmentalhealthassessment&treatment
N' Maintainorseekfull-timeemployment/education STIP$8.5milliondo///rbond
NV Nocontuctwithvictims/witnesses,exceptthroughcounsel; w/$200Kcashcomponenttobe
GovttoprovideIisttoDefense& uspo w/in24brs. fostedby8/16/24 (nobrg.heldl;
Nr Nofirearms Courtsets
NV Nottoencumberhis2properties
Nr Maynotvisittransportationestablishments (releused)
SV HomeConfinement/
curfew
ElectronicMonit
pm to
oringand/or
am wgsrady ordergiven**
, paid by

n Allowances:Medicalneeds,courtappearances,attorneyvisits,
religious,em ploym ent Time from today to excluded
Nv Truvelextendedto: s/ooyFl&Nm olFlw/priornoticetoPTs fromSpeedyTrialClock
Nl- other:
NEXT COURT APPEARANCE Date: Tïm e: Judge: Place:
ReportaEcounsel: 9/3/24 10.
.00a.m . Duty/M iam i
PTD/Bond Hearing:
Arraignment: 9/3/24 10:00u.m. Duty/M ium i
status conference RE:
D .A.R. 14:31:14 Tim e in Court: 10 m ins
s/Lauren F.Louis MagistrateJudge
 Case 1:24-cr-20343-KMW Document 21 Entered on FLSD Docket 08/13/2024 Page 1 of 1
M IN UTE O RDER Page6
M agistrate Judge Lauren F.Louis
AtkinsBuildingCourthouse-11th Floor Date:8/12/24 Time:2:00p.m.
Defendant: 3)JorgeMiguelVasquez J#:29760-511 Case#: 24-20343-CR-W ILLIAMS
AUSA: Rob Emery/collin Mullin Attorney: FrankRubin (Perm)
Violation: MoneyLaundering surr/ArrestDate:8/12/24 YOB:1961
Proceeding: InitialAppearance CJA Appt:
Bond/PTD Held:f--Yes C No Recom mended Bond:
Bond Setat: Co-signed by:
IV
--Isurrenderand/ordonotobtainpassports/traveldocs Language: Spanish
nv ReporttoPTsasdirected/or x'saweek/monthby Disposition:
phone: xzsaweek/monthinperson . .
Random urine testing by pretrial
Nr services charges
Treatm entasdeem ed necessary
Nr Refrainfrom excessiveuseofalcohol Counselfilestemporaryappearance
Nr participateinmentalhealthassessment&treatment
NV Maintainorseekfull-timeemployment/education SFIP$1milliondo///l-bolldw/10%
NV Nocontactwfthvictims/witnesses,exceptthroughcounsel cosignedbyhisAl Te(lsabel
Govttoprovidelisttooefense& uspo w/in24hrs. Hernandez)(courtinquired olthe
Nr Nofirearms Cosignor)(nohrg.heldk Courtsets
Nv Nottoencumberproperty;includingcosignor
Nr Maynotvisittransportationestablishments (released)
Nr Homeconfinement/ElectronicMonitoringand/or *ssradyordergiven**
curfew pm to am ,paid by
Allow ances:M edicalneeds,courtappearances,attorney visits,
religious,em ploym ent
Nr Travelextendedto: Timefromtoda to excluded
NC other: fromspeedyTrialclock
NEXT COURT APPEARANCE Date: Time: Judge: Place:
ReportRE CounseI:
PTD/Bond Hearing:.
Prelim/ArraignorRemoval'
.
Status Conference RE:
D.A.R. 14:31:14/14:42:46 Time in Court: 10 mins
s/l-aurenF.Louis MagistrateJudge
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 1 of 31

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
24-20343-CR-WILLIAMS/GOODMAN
CASE NO. --------
18 u.s.c. § 371
15 U.S.C. § 78dd-2
15 U.S.C. § 78dd-3
18 U.S.C. § 1956(h)
18 U.S.C. § 1956(a)(2)(A )
18 U.S.C. § 1956(a)(2 )(B)(i)
18 U.S.C. § 1957(a)
18 U.S.C. § 981(a)(l)(C)
18 U.S.C. § 982(a)(l)
18 u.s.c. § 2 MP
UNITED STATES OF AMERICA
Aug 8, 2024
vs.

JUAN ANDRES DONATO BAUTISTA, Miami

ROGER ALEJANDRO PINATE MARTINEZ,

JORGE MIGUEL VASQUEZ, and
ELIE MORENO,

Defendants.
--------------
INDICTMENT
The Grand Jury charges that:
GENERAL ALLEGATIONS
At all times relevant to this Indictment:

Relevant Statutory Background

1. The Foreign Corrupt Practices Act of 1977, as amended, Title 15, United States

Code, Sections 78dd-1, et seq. (the "FCPA"), was enacted by Congress for the purpose of, among

other things, making it unlawful for certain classes of persons and entities to act corruptly in

furtherance of an offer, promise, authorization, or payment of money or anything of value to a

foreign government official for the purpose of influencing the foreign official. inducing the foreign
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 2 of 31

official to take or omit certain acts, and securing an improper advantage in order to assist those

classes of persons in obtaining or retaining business for, or directing business to, any person.

Relevant Individuals and Entities

2. The Commission on Elections ("COMELEC") of the Republic of the Philippines

("the Philippines") was an independent agency mandated to enforce and administer election laws

in the Philippines. COMELEC was a "department," "agency," and "instrumentality" of the

Philippines as those terms are used in the FCPA, Title 15, United States Code, Sections 78dd-

2(h)(2)(A) and 78dd-3(f)(2)(A).

3. JUAN ANDRES DONATO BAUTISTA served as the Chairman of COMELEC

from on or about April 28, 2015, to in or around October 2017. BAUTISTA was a "foreign

official" as that term is defined in the FCPA, Title 15, United States Code, Sections 78dd-

2(h)(2)(A) and 78dd-3(f)(2)(A).

4. Company 1, an entity whose identity is known to the Grand Jury, was an election

voting machine and service provider company that was privately held under a parent holding

company. Company 1 was headquartered in the United Kingdom and had offices in several

countries throughout the world .

5. Company 2, an entity whose identity is known to the Grand Jury, was a subsidiary

of a parent holding company and Company 1, was incorporated in Delaware and was registered

in Florida in or around July 2012 with an address in Boca Raton, Florida. Company 2 was a

"domestic concern" as that term is used in the FCPA, Title 15, United States Code, Section 78dd-

2(h)(l).

6. Company 3, an entity whose identity is known to the Grand Jury, was a joint-

venture and subsidiary of a parent holding company and Company 1 that was formed in the

2
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 3 of 31

Philippines in or around 2015 to bid for contracts relating to the 2016 elections in the Philippines.

The joint venture included, among others, Company 1 and Vendor A (described below).

7. ROGER ALEJANDRO PINATE MARTINEZ, a citizen of Venezuela, was a co-

founder, Chief Operating Officer, and President of Company 1. PINATE served on the Board of

Directors for the parent holding company and Company 1 and was an employee of Company 2.

PINATE was a resident of Boca Raton, Florida, in the Southern District of Florida. PINATE was

a "domestic concern" and an "officer," "employee," and "agent" of a "domestic concern" and a

"stockholder" thereof acting on behalf of such "domestic concern," as those terms are used in the

FCPA, Title 15, United States Code, Sections 78dd-2(a) and 78dd-2(h)(l).

8. JORGE MIGUEL VASQUEZ, a citizen of the United States, was an executive

for Company 2 in Boca Raton, Florida who managed hardware development and manufacturing

worldwide for Company 1. He reported to ROGER ALEJANDRO PINATE MARTINEZ.

VASQUEZ was a resident of Davie, Florida, in the Southern District of Florida. VASQUEZ was

a "domestic concern" and an "officer," "employee," and "agent" of a "domestic concern," and a

"stockholder" thereof acting on behalf of a "domestic concern," as those terms are used in the

FCPA, Title 15, United States Code, Sections 78dd-2(a) and 78dd-2(h)(l).

9. ELIE MORENO, a dual citizen of Venezuela and Israel, was a Company 1

executive involved in managing Companies 1 and 3's contracts with COMELEC in the

Philippines. He served as project director for Company 3 and a Company 1 subsidiary in the

Philippines, and he signed and implemented the 2016 Philippine elections contracts with

COMELEC.

10. Individual 1, a dual citizen of Venezuela and Portugal, and whose identity is known

to the Grand Jury, had a business relationship with Company 1 and its subsidiaries. Individual 1

3
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 4 of 31

owned, had an interest in, and controlled multiple offshore companies and bank accounts,

including Hong Kong Company 1, whose identity is known to the Grand Jury, and its bank account

in United Arab Emirates.

11. Vendor A, an entity whose identity is known to the Grand Jury, was a company

based in Taiwan that manufactured hardware for electronic products for Companies 1, 2, and 3.

Vendor A partnered with Company 1 to form the joint venture with Company 3 that bid on and

was awarded contracts to supply voting machines to the Philippines for its 2016 elections.

12. Vendor A-Executive, an individual whose identity is known to the Grand Jury, was

an executive and owner of Vendor A. Vendor A-Executive was an "agent" of a domestic concern

as that term is used in the FCPA, Title 15, United States Code, Sections 78dd-(2)(a) and (h)(l).

13. Baumann Enterprises Limited ("Baumann") was a foreign shell company

incorporated in the British Virgin Islands in or around 2010. JUAN ANDRES DONATO

BAUTISTA as well as two relatives owned and were beneficial owners of Baumann. BAUTISTA

owned and exercised control over Baumann and its bank account in Singapore ending in 2411

("Baumann Bank Account 2411").

14. Shell Company X, an entity whose identity is known to the Grand Jury, was a

foreign shell company incorporated in Anguilla in or around 2014. Vendor A-Executive owned

and exercised control over Shell Company X and its bank account in Hong Kong ending in 271-

838 ("Hong Kong Bank Account 271-838").

15. Shell Company Y, an entity whose identity is known to the Grand Jury, was a

foreign shell company incorporated in Brunei in or around 2011. A relative of Vendor A-Executive

was listed as a director of Shell Company Y and the primary account user for Shell Company Y's

bank account in Hong Kong. Vendor A-Executive owned and exercised control over Shell

4
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 5 of 31

Company Y and its bank account in Hong Kong ending in 796-838 ("Hong Kong Bank Account

796-838").

16. Philippine Metals Company, an entity whose identity is known to the Grand Jury,

was incorporated in the Philippines in or around 1994. Philippine Metals Company represented

itself to be, among other things, an exporter, importer, and manufacturer of metals and metal

products.

17. Philippine MSB Company, an entity whose identity is known to the Grand Jury,

was a registered money services business ("MSB ") incorporated in or around 2010 that operated

in the Philippines.

COMELEC 2016 Philippine Election Contracts

18. In or around October 2014, COMELEC opened the bidding process for the lease

of, with an option to buy, 23,000 election machines and related services for the 2016 Philippine

elections ("Contract 1").

19. On or about August 1, 2015, COMELEC awarded Contract 1 to Company 3. ELIE

MORENO, as Project Director, and on behalf of Company 3, and another COMELEC

commissioner, on behalf of COMELEC, signed Contract 1 because JUAN ANDRES DONATO

BAUTISTA was unavailable. For Contract 1, COMELEC agreed to pay Company 3

1,724,712,698.24 Philippine pesos (approximately $37,038,502.80 in U.S. dollars), in

installments, and upon Company 3 meeting certain milestones during the contract. The contract

provided that COMELEC would issue a payment to Company 3 only when BAUTISTA or his

designee certified that Company 3 had reached a milestone.

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Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 6 of 31

20. In or around May 2015, COMELEC opened the bidding process for the lease of,

with the option to buy, 70,977 election machines and related services for the 2016 Philippine

elections ("Contract 2").

21. On or about August 27, 2015, COMELEC awarded Contract 2 to Company 3.

JUAN ANDRES DONATO BAUTISTA, as COMELEC Chairman, and ELIE MORENO, as

Project Director, and on behalf of Company 3, signed Contract 2. For Contract 2, COMELEC

agreed to pay Company 3 6,286,382,682.72 Philippine pesos (approximately $134,670,877.27 in

U.S. dollars), in installments, and upon Company 3 meeting milestones during the contract.

Contract 2 provided that COMELEC would pay Company 3 only when BAUTISTA or his

designee certified that Company 3 reached a milestone.

22. In or around March 2015, COMELEC opened the bidding process for services

related to transmission of results for the 2016 elections ("Contract 3"). On or about December 8,

2015, COMELEC awarded Contract 3 to a subsidiary of Company 1 for the 2016 Philippine

elections. JUAN ANDRES DONATO BAUTISTA, as COMELEC Chairman, and ELIE

MORENO, as Project Director, and on behalf of the Company 1 subsidiary, signed Contract 3.

For Contract 3, COMELEC agreed to pay the Company 1 subsidiary 507,718,000 Philippine pesos

(approximately $10,642,488.37 in U.S. dollars), in installments, and upon the Company 1

subsidiary meeting milestones during the contract. Contract 3 provided that COMELEC would

pay the Company 1 subsidiary only when BAUTISTA or his designee certified that the Company

1 subsidiary had met a milestone.

23. In total, in or around and between 2015 and 2016, Company 3 and the Company 1

subsidiary won bids for Contracts 1, 2, and 3 worth a total approximate value of 8,518,813,380.96

Philippine pesos (approximately $182,351,868.44 U.S. dollars) to supply COMELEC with voting

6
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 7 of 31

machines and related services for the May 2016 elections in the Philippines for President, Vice­

President, and other official positions.

COUNTl
Conspiracy to Violate the Foreign Corrupt Practices Act
(18 u.s.c. § 371)

1. The General Allegations section of this Indictment is re-alleged and incorporated

by reference as though fully set forth herein.

2. Beginning in or around May 2015 and continuing through in or around February

2018, in Miami-Dade, Broward, and Palm Beach Counties, in the Southern District of Florida, and

elsewhere, the defendants,

ROGER ALEJANDRO PINATE MARTINEZ and

JORGE MIGUEL VASQUEZ,

did knowingly and willfully, that is, with the intent to further the objects of the conspiracy,

combine, conspire, confederate and agree with each other and with others known and unknown to

the Grand Jury, to commit an offense against the United States, that is:

a. being a domestic concern, and an officer, director, employee, and agent of a

domestic concern, and a stockholder thereof acting on behalf of a domestic concern, to willfully

and corruptly make use of the mails and means and instrumentalities of interstate commerce in

furtherance of an offer, payment, promise to pay, and authorization of the payment of money, offer,

gift, promise to give, and authorization of the giving of anything of value to a foreign official, and

to a person, while knowing that all or a portion of such money and thing of value would be and

had been offered, given, and promised to a foreign official, for purposes of: (i) influencing acts

and decisions of such foreign official in his or her official capacity; (ii) inducing such foreign

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 foreign official to use his or her influence with a

7
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 8 of 31

foreign government, departments, agencies and instrumentalities thereof to affect and influence

acts and decisions of such government, departments, agencies and instrumentalities, in order to

assist ROGER ALEJANDRO PINATE MARTINEZ, JORGE MIGUEL VASQUEZ, and

others in obtaining and retaining business for and with, and directing business to Company 1,

Company 1 subsidiary, Company 2, Company 3, Vendor A, and others, in violation of Title 15,

United States Code, Section 78dd-2; and

b. while in the territory of the United States, to willfully and corruptly make use of

the mails and means and instrumentalities of interstate commerce and do any other act in

furtherance of an offer, payment, promise to pay, and authorization of the payment of money, offer,

gift, promise to give, and authorization of the giving of anything of value to a foreign official, and

to a person, while knowing that all or a portion of such money and thing of value would be and

had been offered, given, and promised to a foreign official, for purposes of: (i) influencing acts

and decisions of such foreign official in his or her official capacity; (ii) inducing such foreign

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 foreign official to use his or her influence with a

foreign government, departments, agencies, and instrumentalities thereof to affect and influence

acts and decisions of such government, departments, agencies, and instrumentalities, in order to

assist ROGER ALEJANDRO PINATE MARTINEZ and others in obtaining and retaining

business for and with, and directing business to, Company 1, Company 1 subsidiary, Company 2,

Company 3, Vendor A, and others, in violation of Title 15, United States Code, Section 78dd-3.

Purpose of the Conspiracy

3. It was a purpose of the conspiracy for ROGER ALEJANDRO PINATE

MARTINEZ, JORGE MIGUEL VASQUEZ, and their co-conspirators to offer, promise to pay,

8
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 9 of 31

and pay bribes to JUAN ANDRES DONATO BAUTISTA, a Philippine government official, in

order to obtain and retain contracts with, and receive payment including releases of value added

tax ("VAT") payments from COMELEC, for and with, and direct business to Company 1,

Company 1 subsidiary, Company 2, Company 3, Vendor A, and others. It was further a purpose

of the conspiracy to conceal the bribe payments, proceeds, and funds related to the corrupt scheme.

Manner and Means of the Conspiracy

The manner and means by which ROGER ALEJANDRO PINATE MARTINEZ,

JORGE MIGUEL VASQUEZ and their co-conspirators sought to accomplish the objects and

purposes of the conspiracy included, among other things, the following:

4. ROGER ALEJANDRO PINATE MARTINEZ, JORGE MIGUEL VASQUEZ,

and ELIE MORENO, together with others, regularly communicated about corrupt payments to

and for the benefit of JUAN ANDRES DONATO BAUTISTA using personal or non-business

email accounts, as well as encrypted messaging on WhatsApp, to conceal the nature of the

communications.

5. ROGER ALEJANDRO PINATE MARTINEZ, JORGE MIGUEL VASQUEZ,

and ELIE MORENO, together with others, created and used slush funds to, among other things,

pay bribes to JUAN ANDRES DONATO BAUTISTA, including by over-invoicing or inflating

the cost per voting machine for the May 2016 Philippine elections with additional fees of $50 and

$10 per unit. PINATE, VASQUEZ, and others further caused transfers of monies from slush

funds to, through, and from bank accounts and companies controlled by PINATE, VASQUEZ,

and others including bank accounts and companies located in Hong Kong; Singapore; the

Philippines; Switzerland; New York; and Weston, Florida; and elsewhere.

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6. To conceal and disguise the nature and purpose of the slush funds, JORGE

MIGUEL VASQUEZ and others described in coded language the slush funds generated by the

additional $50 fee as the "boss's funds," "RUSH fee" or "Extra Fee[s]," and the funds generated

by the additional$10 per unit as the "RUE."

7. ROGER ALEJANDRO PINATE MARTINEZ, JORGE MIGUEL VASQUEZ,

and ELIE MORENO, together with others, caused fraudulent contracts and sham loan agreements

to be created from various offshore entities that described services and loans that were not provided

to generate funds for corrupt payments from the slush funds for the benefit of JUAN ANDRES

DONATO BAUTISTA.

8. ROGER ALEJANDRO PINATE MARTINEZ, JORGE MIGUEL VASQUEZ,

and ELIE MORENO, together with others, caused corrupt payments to be made for the benefit

of JUAN ANDRES DONATO BAU TISTA through a series of transactions, initiating in the

Southern District of Florida and elsewhere, involving a network of offshore and domestic bank

accounts, intermediaries, and shell and front companies including by Shell Company X and Shell

Company Y, which were owned and controlled by Vendor A-Executive, and Philippine Metals

Company and Philippine MSB Company.

9. ROGER ALEJANDRO PINATE MARTINEZ, JORGE MIGUEL VASQUEZ,

and ELIE MORENO, together with others, directed and caused Vendor A-Executive to use

domestic and overseas bank accounts to transfer and to attempt to transfer approximately

$1,000,000 in bribe payments to and for the benefit of JUAN ANDRES DONATO BAUTISTA.

10. To promote the bribery scheme and conceal the proceeds, using the funds received

from Vendor A-Executive, JUAN ANDRES DONATO BAUTISTA wired and caused the wire

transfer of$960,000, purportedly as a "gift," from Baumann Bank Account 2411 to a bank account
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 11 of 31

in New York held in the name of a family member, which the family member then used to purchase

a property in San Francisco, California.

Overt Acts

In furtherance of the conspiracy, and to accomplish the purposes and objects thereof,

ROGER ALEJANDRO PINATE MARTINEZ, JORGE MIGUEL VASQUEZ, their co­

conspirators, and others, committed and caused to be committed, in the Southern District of

Florida, and elsewhere, at least one of the following overt acts, among others:

1. On or about May 16, 2015, ROGER ALEJANDRO PINATE MARTINEZ sent

JORGE MIGUEL VASQUEZ a WhatsApp message stating, in Spanish, that he was "screwed

here in the Philippines they want to eliminate us, and I am fighting it to the death ...."

2. Shortly after he sent the prior message referenced in Paragraph 1 above, on or about

May 16, 2015, ROGER ALEJANDRO PINATE MARTINEZ sent JORGE MIGUEL

VASQUEZ a follow-up WhatsApp message communicating, in Spanish, that "the BaC [Bids and

Awards Committee] has two members bought by [ a competitor] of the 5" members.

3. On or about March 31, 2016, JORGE MIGUEL VASQUEZ emailed Vendor A-

Executive to caution him that "[s]ince there are some other fees involved that [a Vendor A

employee] shouldn't be aware, let's discuss it (using those emails addresses) among us first and

then you can notify [the Vendor A employee] of the final cost (without mentioning the other fees)."

4. On or about April 12, 2016, using personal email addresses, ROGER

ALEJANDRO PINATE MARTINEZ emailed JORGE MIGUEL VASQUEZ to introduce

VASQUEZ to Individual 1 and to arrange a meeting between VASQUEZ and Individual 1 in

Weston, Florida, in the Southern District of Florida.

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Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 12 of 31

5. On or about May 15, 2016, ROGER ALEJANDRO PINATE MARTINEZ, via

personal email, instructed JORGE MIGUEL VASQUEZ to "create the contract you need" to

begin making payments to a bank account associated with Philippine Metals Company

("Philippine Metals Company Bank Account 0419").

6. On or about May 16, 2016, JORGE MIGUEL VASQUEZ emailed Vendor A-

Executive that he had a meeting with his "boss" and Individual 1 the day before, and that they

considered another company to use "in the future for the kind of transactions we have to make. I

[t]hink it is a good idea that we have many ways to route the transactions so we minimize the

transfers to 1 or 2 companies. The idea is to use this company, as a 'sales representative' of [Vendor

A], so if in the future we need to [sic] something, [Company 1] can place a PO for some service

or items to [Ifong Kong Company 1], and such company place a PO to [Vendor A] for less amount,

keeping some 'profit' or funds in such company we could use for other purposes."

7. On or about May 19, 2016, ELIE MORENO, using another personal email

address, forwarded a sham contract to ROGER ALEJANDRO PINATE MARTINEZ, at a

personal email account. The contract listed a schedule of multiple payments from Shell Company

X to Philippine Metals Company for a total of $1,350,000 for the purported purchase of iron ore

and copper.

8. On or about May 20, 2016, JORGE MIGUEL VASQUEZ sent an email to

ROGER ALEJANDRO PINATE MARTINEZ, in Spanish, advising PINATE to modify the

service clause of the contract between Shell Company X and Philippines Metals Company based

on "whatever comes to mind ... [use] the imagination ... hahahahahaha."

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9. On or about June 2, 2016, JORGE MIGUEL VASQUEZ directed and caused

Vendor A-Executive to wire transfer approximately $350,000 from Shell Company X to Philippine

Metals Company for a fictitious purchase of iron ore and copper.

10. On or about July 21, 2016, ROGER ALEJANDRO PINATE MARTINEZ sent

JORGE MIGUEL VASQUEZ an email, in Spanish, directing VASQUEZ "not to make any more

payments until I let you know because they owe us."

11. On or about July 29, 2016, ELIE MORENO, on behalf of Company 3, sent JUAN

ANDRES DONATO BAUTISTA, in his capacity as COMELEC Chairman, a letter requesting

that BAUTISTA use his "good office to approve the release of our outstanding collectible totaling

Php 3.3 Billion (inclusive of 12% VAT)" (approximately $70,132,635.69 in U.S. dollars).

12. On or about August 3, 2016, JORGE MIGUEL VASQUEZ emailed ROGER

ALEJANDRO PINATE MARTINEZ, in Spanish: "It's important that you come to Taiwan

sometime when I'm here to rub the nephew's back! He is really helping us and I would like him

to know (verbally) that this is a favor to the company!"

13. On or about August 3, 2016, ROGER ALEJANDRO PINATE MARTINEZ

created and caused to be created a sham draft loan agreement for Shell Company X.

14. On or about August 10, 2016, JORGE MIGUEL VASQUEZ, messaged via

WhatsApp to ROGER ALEJANDRO PINATE MARTINEZ, in Spanish, that he would send the

wire transfer the following week in connection with the loan contract, but that he was concerned

about doing so because the wire transfer involved "this country" and the country could be a "pain."

15. On or about August 10, 2016, ROGER ALEJANDRO PINATE MARTINEZ,

later messaged, in Spanish, via WhatsApp to JORGE MIGUEL VASQUEZ, informing him that

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Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 14 of 31

"[i]t seems that we are close to achieving the goal of collecting, and in addition collecting much

more than what was hoped for through a tax strategy, we are close."

16. On or about August 11, 2016, ELIE MORENO sent an email to ROGER

ALEJANDRO PINATE MARTINEZ and JORGE MIGUEL VASQUEZ with payment

instructions for Baumann Bank Account 2411 and a sham loan agreement between Shell Company

X and Baumann.

17. On or about August 15, 2016, several days after JUAN ANDRES DONATO

BAUTISTA approved the payment of 195,663,660.99 Philippine pesos (approximately

$4,208,454.20 in U.S. dollars) to Company 3 relating to a release of VAT withheld from Contract

2, ROGER ALEJANDRO PINATE MARTINEZ, while in the Southern District of Florida, sent

JORGE MIGUEL VASQUEZ a WhatsApp message, in Spanish, that "Elie [MORENO] sends

you the instructions but they already started paying us so we can immediately execute the loan."

18. On or about August 15, 2016, replying to an email from JORGE MIGUEL

VASQUEZ, and copying ROGER ALEJANDRO PINATE MARTINEZ, ELIE MORENO

wrote that the wiring instruction to Baumann Bank Account 2411 "[l]ooks ok. Checking to be

safe."

19. On or about August 15, 2016, ROGERALEJANDRO PINATE MARTINEZ and

JORGE MIGUEL VASQUEZ, while both in the Southern District of Florida, engaged in a

WhatsApp conversation, in Spanish, about payments to Philippine Metals Company, in which

VASQUEZ advised PINATE that he was working on the "loan," but warned that they may have

to change the entities involved since the two they have used are overexposed.

a. In the same WhatsApp conversation, JORGE MIGUEL VASQUEZ wrote, in

Spanish, to ROGER ALEJANDRO PINATE MARTINEZ that "my pal is

14
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 15 of 31

*hitting himself because it is a lot in one shot so that I have to do 2 documents

for 500 each one!"

b. In the same WhatsApp conversation, in Spanish, JORGE MIGUEL

VASQUEZ wrote to ROGER ALEJANDRO PINATE MARTINEZ that the

loan has to be done well because it is a lot of money to pass through the United

States, which "sets off a lot of alarms."

20. On or about August 16, 2016, JORGE MIGUEL VASQUEZ sent ROGER

ALEJANDRO PINATE MARTINEZ a WhatsApp message, in Spanish, informing him that the

$1,000,000 loan payment had to be divided into two payments with 500 being "lent'' by Shell

Company X and 500 by Shell Company Y because it was a lot of"salsa'' to send to the "north."

21. On or about August 16, 2016, ROGER ALEJANDRO PINATE MARTINEZ and

JORGE MIGUEL VASQUEZ directed and caused Vendor A-Executive to send and attempt to

send a wire transfer in the amount of approximately $500,000 for a sham loan from Shell Company

Y, through an intermediary bank in New York, to Baumann Bank Account 2411 in Singapore.

22. On or about August 18, 2016, ROGER ALEJANDRO PINATE MARTINEZ and

JORGE MIGUEL VASQUEZ engaged in a WhatsApp conversation, in Spanish, about payments

regarding the sham loan, in which VASQUEZ expressed concerns about sending "a lot of money

in the same week. If they had not asked to send them to the usa there would not have been a

problem but sending them to the usa is what complicated everything."

23. On or about August 22, 2016, ROGER ALEJANDRO PINATE MARTINEZ,

JORGE MIGUEL VASQUEZ and others directed and caused Vendor A-Executive to send and

attempt to send a wire transfer in the amount of approximately $500,000 for a sham loan from

15
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 16 of 31

Shell Company X, through an intermedi ary bank in New York, to Baumann Bank Account 2411

in Singapore.

24. On or about August 31, 2016, ROGER ALEJANDRO PINATE MARTINEZ,

JORGE MIGUEL VASQUEZ and others directed and caused Vendor A-Executive to send and

attempt to send a wire transfer in the amount of approximately $500,000 for a sham loan from

Shell Company Y, through an intermedi ary bank in New York, to Baumann Bank Account 2411 in

Singapore.

25. On or about September 29, 2016, Vendor A-Executive wrote to JORGE MIGUEL

VASQUEZ, using personal email addresses, "O]ust in case, ifbank request us to provide some

document to proof [sic] the purpose of transfer, [w]ould you please help to send the Loan

Agreement copy (with both sign [sic]) to us for the record? Thank you~"

26. On or about October 7, 2016, JORGE MIGUEL VASQUEZ emailed Vendor A-

Executive signed copies ofsham loan contracts between Shell Companies X and Y and Baumann

that ELIE MORENO had emailed to VASQUEZ one day before.

27. On or about October 17, 2016, JORGE MIGUEL VASQUEZ-after learning that

JUAN ANDRES DONATO BAUTISTA had failed to convince bank officials at a bank in

Singapore that the two August 2016 loans agreements between Baumann and Shell Company X

and Shell Company Y, respectively, were legitimate, and that the approximately $1,000,000 had

been returned to Shell Companies X and Y-sent an email to Vendor A-Executive, that he would

inform him later how to "use those funds."

28. On or about December 6, 2016, JORGE MIGUEL VASQUEZ emailed Vendor A-

Executive the following instructions:

Remember the 2 500's T/T returned?

We need to pay that 1 MM to [Philippine Metals Company].

16
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 17 of 31

You did some transfers before to them, so you should have all the information; the
contract is still valid so I think it should not be a problem to pay them.
Please let me know what do you need in order to start sending the payments ...
I suggest to send as follows:

WED 07DEC 297,500$

FRI 09DEC 262,700$
TUE 12DEC 268,800$
THU 14DEC 71,000$

29. On or about December 6, 2016, JORGE MIGUEL VASQUEZ, in a reply email

to Vendor A-Executive, wrote that "I prefer to do the first one ASAP in order to calm down the

recipient people ...Worst case scenario you can not do it tomorrow, follow your suggestion but be

sure we follow the schedule. Send me the TIT confirmations once you have them!"

30. On or about December 7, 2016, using personal email addresses, JORGE MIGUEL

VASQUEZ emailed ROGER ALEJANDRO PINATE MARTINEZ and ELIE MORENO wire

confirmation of a payment sent by Shell Company X to Philippine Metals Company Bank Account

0419 in the amount of approximately $297,500.

31. On or about January 3, 2017, ROGER ALEJANDRO PINATE MARTINEZ,

JORGE MIGUEL VASQUEZ, their co-conspirators, and others caused the following emails to

be sent:

a. On or about January 3, 2017, an individual emailed ELIE MORENO an

updated sham contract between Philippine Metals Company and Shell

Company X for the purchase of iron ore and copper.

b. On or about January 3, 2017, an employee of an attorney emailed an unknown

person wire transfer confirmation of $262,700 from Shell Company X to

Philippine Metals Company.

17
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 18 of 31

c. On or about January 3, 2017, an employee of an attorney sent an attorney an

email informing the attorney that Philippines Metals Company had received

$262,000.

32. On or about February 9, 2017, using personal email addresses, JORGE MIGUEL

VASQUEZ emailed ROGER ALEJANDRO PINATE MARTINEZ and ELIE MORENO wire

confirmation of a payment sent by Shell Company X to Philippine Metals Company Bank.Account

0419 in the amount of approximately $268,772.

33.. On or about February 9, 2017, using personal email addresses, JORGE MIGUEL

VASQUEZ sent an email informing ELIE MORENO that the payments referenced in Paragraph

28 had been made to Philippine Metals Company. VASQUEZ further wrote, in Spanish, to

ROGER ALEJANDRO PINATE MARTINEZ and MORENO that "[t]his would be the status

of the new batch (after the previous original plan had to be reversed and re-routed.)"

34. On or about February 16, 2017, Philippine Metals Company wired approximately

$268,772 from Philippine Metals Company Bank Account 0419 to a Philippine MSB Company

bank account ending in 0212.

35. Shortly thereafter, ROGER ALEJANDRO PINATE MARTINEZ, JORGE

MIGUEL VASQUEZ, and ELIE MORENO caused Vendor A-Executive to send a wire on or

about February 22, 2017, in the approximate amount of $71,000 from Shell Company X to

Philippine Metals Company.

36. On or about August 10, 2017, using personal email accounts, Vendor A-Executive

emailed JORGE MIGUEL VASQUEZ an Excel spreadsheet that detailed "Extra Fee" and "Rue"

payments from Shell Company X to Baumann, Philippine Metals Company, and other entities.

18
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 19 of 31

37. On or about February 19, 2018, an employee for an attorney sent an attorney an

email with the subject line, "Reconciliation of Accounts, 10-30-17 Final" with an Excel

spreadsheet titled "Reconciliation - ELI MORENOv9," which included the redirected payments

referenced in Paragraph 28.

All in violation ofTitle 18, United States Code, Section 371.

COUNT2
Foreign Corrupt Practices Act
(15 U.S.C. § 78dd-2)

1. The General Allegations section ofthis Indictment are re-alleged and incorporated

by reference as though fully set forth herein.

2. On or about August 15, 2016, in Broward and Palm Beach Counties, in the Southern

District ofFlorida, and elsewhere, the defendants,

ROGERALEJANDRO PINATE MARTINEZ and

J ORGE MIGUEL VASQUEZ,

being a domestic concern and an officer, director, employee and agent of a domestic concern, and

a stockholder thereof acting on behalf ofa domestic concern, did willfully and corruptly make use

and cause to be used, and aid, abet, and willfully cause others to make use of the mails and means

and instrumentalities of interstate commerce in furtherance of an offer, payment, promise to pay,

and authorization of the payment of money, offer, gift, promise to give, and authorization of the

giving ofanything ofvalue to a foreign official, and to a person, while knowing that all or a portion

of such money and thing ofvalue would be and had been offered, given, and promised to a foreign

official, for purposes of: (i) influencing acts and decisions of such foreign official in his or her

official capacity; (ii) inducing such foreign 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 foreign

official to use his or her influence with a foreign government, departments, agencies, and

19
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 20 of 31

instrumentalities thereof to affect and influence acts and decisions of such government and

agencies and instrumentalities, in order to assist ROGER ALEJANDRO PINATE MARTINEZ,

JORGE MIGUEL VASQUEZ, and others in obtaining and retaining business for and with, and

directing business to, Company 1, Company 1 subsidiary, Company 2, Company 3, Vendor A, and

others, to wit, PINATE sent VASQUEZ a WhatsApp message relating to payments received from

COMELEC and the instruction to immediately execute a loan that would be used to facilitate a

payment for the benefit of JUAN ANDRES DONATO BAUTISTA in furtherance of the illegal

bribery scheme.

In violation of Title 15, United States Code, Sections 78dd-2 and Title 18, United States

Code, Section 2.

COUNT3
Conspiracy to Commit Money Laundering
(18 U.S.C. § 1956(h))

1. The General Allegations section and Paragraphs 4 through 10 of the Manner and

Means section of Count 1 are re-alleged and incorporated by reference as though fully set forth

herein.

2. From in or around May 2015 and continuing until at least February 2018, in Miarni-

Dade, Broward, and Palm, Beach Counties, in the Southern District of Florida, and elsewhere, the

defendants,

JUAN ANDRES DONATO BAUTISTA,

ROGER ALEJANDRO PINATE MARTINEZ,
JORGE MANUEL VASQUEZ, and
ELIE MORENO,

did knowingly and voluntarily combine, conspire, confederate, and agree with each other and with

persons known and unknown to the Grand Jury, to commit offenses defined in Title 18, United

States Code, Section 1956, namely:

20
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 21 of 31

a. to knowingly transport, transmit, and transfer, and attempt to transport, transmit,

and transfer, a monetary instrument and funds from a place in the United States to and through a

place outside the United States, and to a place in the United States from and through a place outside

the United States, knowing that the monetary instrument and funds involved in the transportation,

transmission, and transfer represent the proceeds of some form of unlawful activity and knowing

that such transportation, transmission, and transfer was designed in whole and in part to conceal

and disguise the nature, the location, the source, the ownership, and the control of the proceeds of

specified unlawful activity, in violation of Title 18, United States Code, Section 1956(a)(2)(B)(i);

b. to knowingly transport, transmit, and transfer, and attempt to transport, transmit,

and transfer, a monetary instrument and funds from a place in the United States to and through a

place outside the United States, and to a place in the United States from and through a place outside

the United States, with the intent to promote the carrying on of a specified unlawful activity, in

violation of Title 18, United States Code, Section 1956(a)(2)(A); and

c. to knowingly engage and attempt to engage in a monetary transaction affecting

interstate and foreign commerce, by, through and to a fmancial institution, in criminally derived

property of a value greater than $10,000, such property having been derived from a specified

unlawful activity, and knowing that the property involved in the financial transactions represented

the proceeds of some form of unlawful activity, in violation ofTitle 18, United States Code, Section

1957(a).

It is further alleged that the specified unlawful activity is:

(a) a felony violation of the Foreign Corrupt Practices Act, Title 15, United States Code,

Sections 78dd-2 and 78dd-3; and

(b) an offense against a foreign nation, specifically the Philippines, involving bribery of a

21
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 22 of 31

public official, and the misappropriation, theft, and embezzlement of public funds by and for the

benefit of a public official as provided by Title 18, United States Code, Section 1956(c)(7)(B)(iv).

All in violation of Title 18, United States Code, Section 1956(h).

COUNTS4-6
International Laundering of Monetary Instruments
(18 U.S.C. § 1956(a )(2)(A))
1. The General Allegations section of this Indictment are re-alleged and incorporated

by reference as though fully set forth herein.

2. On or about the dates specified as to each Count below, in Miami-Dade, Broward,

and Palm Beach Counties, in the Southern District of Florida, and elsewhere, the defendants,

JUAN ANDRES DONATO BAUTISTA,

ROGER ALEJANDRO PINATE MARTINEZ,
JORGE MIGUEL VASQUEZ, and
ELIE MORENO,

did knowingly transport, transmit, and transfer, attempt to transport, transmit, and transfer, and aid,

abet and cause others to do the same, a monetary instrument and funds from a place in the United

States to and through a place outside the United States, and to a place in the United States from

and through a place outside the United States, with the intent to promote the carrying on of a

specified unlawful activity, as set forth below:

Count Approximate Description of Transaction

Date
Wire transfer in the amount of approximately $500,000
4 August 16, 2016 from Shell Company Y's Hong Kong Bank Account 796-
838, through an intermediary bank account in New York,
to Baumann Bank Account 2411 in Singapore.
Wire transfer in the amount of approximately $500,000
5 August 22, 2016 from Shell Company X's Hong Kong Bank Account 271-
838, through an intermediary bank account in New York,
to Baumann Bank Account 2411 in Singapore.
Wire transfer in the amount of approximately $500,000
6 August 31, 2016 from Shell Company Y's Hong Kong Bank Account 796-
838, through an intermediary bank account in New York,
to Baumann Bank Account 2411 in Singapore.

22
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 23 of 31

It is further alleged that the specified unlawful activity is:

(a) a felony violation of the Foreign Corrupt Practices Act, Title 15, United States Code,

Sections 78dd-2 and 78dd-3; and

(b) an offense against a foreign nation, specifically the Philippines, involving bribery of a

public official, and the misappropriation, theft, and embezzlement of public funds by and for the

benefit of a public official as provided by Title 18, United States Code, Section 1956(c)(7)(B)(iv).

In violation of Title 18, United States Code, Sections 1956(a)(2)(A) and 2.

FORFEITURE ALLEGATIONS

1. The allegations of this Indictment are hereby re-alleged and by this reference fully

incorporated herein for the purpose of alleging forfeiture to the United States of America of certain

property in which the defendants, JUAN ANDRES DONATO BAUTISTA, ROGER

ALEJANDRO PINATE MARTINEZ, JORGE MIGUEL VASQUEZ, and ELIE MORENO,

have an interest.

2. Upon conviction of a violation, or conspiracy to commit a violation, of Title 15,

United States Code, Sections 78dd-2 and/or 78dd-3, as alleged in this Indictment, the defendant

shall forfeit to the United States any property, real or personal, which constitutes or is derived from

proceeds traceable to such offense, pursuant to Title 18, United States Code, Section 98l(a)(l)(C).

3. Upon conviction of violation, or conspiracy to commit a violation, of Title 18

United States Code, Sections 1956 and/or 1957, as alleged in this Indictment, the defendants shall

forfeit to the United States any property, real or personal, involved in such offenses, and any

property traceable to such property, pursuant to Title 18, United States Code, Section 982(a)(l).

4. The property subject to forfeiture, as a result of the alleged offenses, includes, but

is not limited to, the following:

23
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 24 of 31

(i) Real property located at 2655 Bush Street, Unit #212, San Francisco, California

94115.

5. If any of the property subject to forfeiture, as a result of any act or omission of the

defendant:

a. Cannot be located upon the exercise of due diligence;

b. Has been transferred or sold to, or deposited with, a third party;

c. Has been placed beyond the jurisdiction of the court;

d. Has been commingled with other property which cannot be divided without

difficulty.

The United States shall be entitled to forfeiture of substitute property under the provisions of Title

21, United States Code, Section 853(p).

All pursuant to Title 18, United States Code, Sections 98l(a)(l)(C) and 982(a)(l), and the

procedures set forth in Title 21, United States Code, Section 853, as incorporated by Title 18,

United States Code, Section 982(b )(1) and Title 28, United States Code, Section 2461(c).

GLENN S. LEON, CHIEF � if -'

FRAUD SECTION UNITED STATES ATTORNEY
CRIMINAL DIVISION
U.S. DEPARTMENT OF JUSTICE

�6,,n
LC. DILORENZO
CONNOR MULLIN
TRIAL ATTORNEYS
ALEXANDER KRA MER
A SSISTA NT CHIEF

24
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 25 of 31
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

UNITED STATES OF AMERICA CASE NO.: 24-20343-CR-WILLIAMS/GOODMAN

_____________

v.
JUAN ANDRES DONATO BAUTISTA, et CERTIFICATE OF TRIAL ATTORNEY
al.,
-----------------I
Defendants. Superseding Case Information:
Court Division (select one) New Defendant(s) (Yes or No) __
IE Miami Cl Key West □ FTP Number of New Defendants
□
FTL CIWPB Total number of new counts

I do hereby certify that:

1. I have carefully considered the allegations of the indictment, the number of defendants, the number of probable
witnesses and the legal complexities of the Indictment/lnformation attached hereto.
2. I am aware that the information supplied on this statement will be relied upon by the Judges of this Court in setting
their calendars and scheduling criminal trials under the mandate of the Speedy Trial Act, Title 28 U.S.C. §3161.

3. Interpreter: (Yes orNo) �

List language and/or dialect: -------
4. This case will take � days for the parties to try.

5. Please check appropriate category and type of offense listed below:

(Check only one) (Check only one)
I □ 0 to 5 days Cl Petty
II □ 6 to 10 days □ Minor
III IE 11 to 20 days □ Misdemeanor
IV Cl 21 to 60 days IE Felony
V Cl 61 days and over
6. Has this case been previously filed in this District Court? (Yes or No) No
If yes, Judge ___________ Case No. ______________ _
7. Has a complaint been filed in this matter? (Yes or No) Yes
If yes, Magistrate Case No. 23-mj-3829-Louis
8. Does this case relate to a previously filed matter in this District Court? (Yes or No) �
If yes, Judge ___________ Case No. _______________ _
9. Defendant(s) in federal custody as of _____________________
10. Defendant(s) in state custody as of
11. Rule 20 from the____District of _________ _
12. Is this a potential death penalty case? (Yes or No) No
13. Does this case originate from a matter pending in the Northern Region of the U.S. Attorney's Office
prior to August 8, 2014 (Mag. Judge Shaniek Maynard? (Yes or No)
14. Does this case originate from a matter pending in the Central Region of the U.S. Attorney's Office prior
to October 3, 2019 (Mag. Judge Jared Strauss? (Yes or No) No
15. Did this matter involve the participation of or consultation with Magistrate Judge Eduardo I. Sanchez
during his tenure at the U.S. Attorney's Office, which concluded on January 22, 2023? No
16. Did this matter involve the participation of or consultation with now Magistrate Judge Marta Fulgueira
Elfenbein during her tenure at the U.S. Attorney's Office, which concluded on March 5, 2024? �

By:

Assistant
Court ID No.
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 26 of 31

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

PENALTY SHEET

Defendant's Name: JUAN ANDRES DONATO BAUTISTA

Case No: _______________________________

Count# 3:

Conspiracy to Engage in Money Laundering

Title 18, United States Code, Section 1956(h)

* Max. Term of Imprisonment: Twenty (20) Years
* Mandatory Min. Term of Imprisonment (if applicable): N/A
* Max. Supervised Release: Three Years
* Max. Fine: $500,000 or twice the value of the property involved in the transaction,
whichever is greater

Counts# 4-6:

Money Laundering

Title 18, United States Code, Section 1956(a)(2)(A)

* Max. Term of Imprisonment: Twenty (20) Years
* Mandatory Min. Term of Imprisonment (if applicable): N/A
* Max. Supervised Release: Three Years
* Max. Fine: $500,000 or twice the value of the property involved in the transaction,
whichever is greater

*Refers only to possible term of incarceration, supervised release and fines. It does not include
restitution, special assessments, parole terms, or forfeitures that may be applicable.
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 27 of 31

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

PENALTY SHEET

Defendant's Name: ROGER ALEJANDRO PINATE MARTINEZ

Case No: -------------------------------

Count# 1:

Conspiracy to Violate the Foreign Corrupt Practices Act

Title 18 United States Code Section 371

*Max. Term of Imprisonment: Five (5) Years
*Mandatory Min. Term of Imprisonment (if applicable): NIA
*Max. Supervised Release: Three Years
*Max. Fine: $500,000 or twice the amount of the financial gain or loss

Count#2:

Violation of the Foreign Corrupt Practices Act

Title 15, United States Code, Sections 78dd-2

*Max. Term of Imprisonment: Five (5) Years
* Mandatory Min. Term of Imprisonment (if applicable): NIA
*Max. Supervised Release: Three Years
* Max. Fine: $500,000 or twice the amount of the financial gain or loss

Count# 3:

Conspiracy to Engage in Money Laundering

Title 18, United States Code, Section 1956(h)

*Max.Term of Imprisonment: Twenty (20) Years
* Mandatory Min. Term of Imprisonment (if applicable): NIA
*Max. Supervised Release: Three Years
*Max.Fine: $500,000 or twice the value of the property involved in the transaction,
whichever is greater

*Refers only to possible term of incarceration, supervised release and fines. It does not include
restitution, special assessments, parole terms, or forfeitures that may be applicable.
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 28 of 31

Counts # 4-6:

Money Laundering

Title 18, United States Code, Section 1956(a)(2)(A)

*Max.Term of Imprisonment: Twenty (20) Years
*Mandatory Min.Term of Imprisonment (if applicable): N/A
*Max. Supervised Release: Three Years
*Max.Fine: $500,000 or twice the value of the property involved in the transaction,
whichever is greater

*Refers only to possible term of incarceration, supervised release and fines. It does not include
restitution, special assessments, parole terms, or forfeitures that may be applicable.
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 29 of 31

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

PENALTY SHEET

Defendant's Name: JORGE MIGUEL VASQUEZ

Case No: _______________________________

Count# 1:

Conspiracy to Violate the Foreign Corrupt Practices Act

Title 18, United States Code, Section 371

*Max.Term of Imprisonment: Five (5) Years
*Mandatory Min.Term of Imprisonment (if applicable): N/A
* Max.Supervised Release: Three Years
*Max.Fine: $500,000 or twice the amount of the financial gain or loss

Count# 2:

Violation of the Foreign Corrupt Practices Act

Title 15, United States Code, Sections 78dd-2

*Max.Term of Imprisonment: Five (5) Years
*Mandatory Min. Term of Imprisonment (if applicable): N/A
*Max.Supervised Release: Three Years
*Max. Fine: $500,000 or twice the amount of the financial gain or loss

Count# 3:

Conspiracy to Engage in Money Laundering

. Title 18, United States Code, Section. 1956(h)

*Max. Term of Imprisonment: Twenty (20) Years
*Mandatory Min.Term of Imprisonment (if applicable): N/A
*Max.Supervised Release: Three Years
*Max.Fine: $500,000 or twice the value of the property involved in the transaction,
whichever is greater

*Refers only to possible term of incarceration, supervised release and fines. It does not include
restitution, special assessments, parole terms, or forfeitures that may be applicable.
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 30 of 31

Counts# 4-6:

Money Laundering

Title 18, United States Code, Section 1956(a)(2)(A)

* Max. Term of Imprisonment: Twenty (20) Years
* Mandatory Min. Term of Imprisonment (if applicable): N/A
* Max. Supervised Release: Three Years
* Max. Fine: $500,000 or twice the value of the property involved in the transaction,
whichever is greater

*Refers only to possible term of incarceration, supervised release and fines. It does not include
restitution, special assessments, parole terms, or forfeitures that may be applicable.
Case 1:24-cr-20343-KMW Document 12 Entered on FLSD Docket 08/09/2024 Page 31 of 31

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

PENALTY SHEET

Defendant's Name: ==�;;..;:;;..;

ELIE MORENO =;.;;..;...;:;._____________________
Case No: -------------------------------
Count# 3:

Conspiracy to Engage in Money Laundering

Title 18, United States Code, Section l 956(h)

*Max.Term of Imprisonment: Twenty (20) Years
*Mandatory Min. Term of Imprisonment (if applicable): N/A
*Max. Supervised Release: Three Years
* Max. Fine: $500,000 or twice the value of the property involved in the transaction,
whichever is greater

Counts# 4-6:

Money Laundering

Title 18, United States Code. Section 1956(a)(2)(A)

*Max.Term of Imprisonment: Twenty (20) Years
* Mandatory Min. Term of Imprisonment (if applicable): N/A
* Max. Supervised Release: Three Years
* Max. Fine: $500,000 or twice the value of the property involved in the transaction,
whichever is greater

*Refers only to possible term of incarceration, supervised release and fines. It does not include
restitution, special assessments, parole terms, or forfeitures that may be applicable.