Professional Crypto Laundering

An Assessment of the Figueira Indictment – Methodology, Red Flags & Actions To Take

📅 March 18, 2026

In January 2026, the U.S. Department of Justice indicted* Venezuelan national Jorge Figueira for laundering almost $1 billion using a highly advanced methodology that included cash, crypto, Over-the-Counter (OTC) brokerages registered in the UK and United States, and shell companies with accounts at regulated financial institutions.

“Do you know who has excellent technology tools to do money laundering? The Chinese. But we do too. I spent money on monitoring, and I have supervision and control tools…” – Jorge Figueira recorded in an FBI audio recording, translated from Spanish

While Chinese Money Laundering Networks (CMLNs) have attracted significant attention – representing $312 billion in suspicious activity reports filed with FinCEN over 2020-2024 – other professional money launderers are also highly effective and financial institutions must ensure they are taking action on these networks and their typologies too.

According to the indictment^, Figueira and his transnational network could also launder at immense and multi-national scale:

More than $70,000-$80,000 per day
$1,000,000 “without issues”
$100,000,000 in “one transfer”
Average of $700,000,000 in transfers per month
Servicing locations all over the world including Argentina, China, Colombia, UAE, Germany, Spain, Venezuela, United States

* A criminal complaint is merely an accusation. The defendant is presumed innocent until proven guilty.

^ Analysis in this article is drawn from Case No. 1:25-mj-730-LRV, except where specified.

Expert Knowledge of Financial Regulations, Controls, and Blockchain

The Figueira indictment reveals the extensive capabilities and advanced knowledge of professional money launderers, making them formidable adversaries for financial institutions. In the investigation and the audio recordings made by the FBI, Figueira demonstrates an understanding of:

S. laws including “the PATRIOT law and RICO law” and their implications for his laundering networks
How to exploit variations in regulation and enforcement across jurisdictions, such as in which countries cash can be deposited to minimize attracting attention
Bank due diligence processes and how to make shell companies appear legitimate, such as creating websites
Bank risk rating methods such as the types of business that attract attention including “money transmitters”, and how to minimize scrutiny
Blockchain analytics, how it can be used to identify wallets associated with illicit activity, and how to monitor wallets to minimize them being frozen

“That’s why I insist a lot about the screening of the wallets… The wallets can be traced. I know how to trace them. But since I know how to trace them, we know how to disguise them… [I spend] around $35,000 monthly, only on tools.”

– Jorge Figueira recorded in an FBI audio recording, translated from Spanish

The Figueira Methodology

Here’s how the Figueira laundering methodology worked:

Step 1: Cash deposits

Cash was deposited into bank accounts in Panama or Venezuela. This cash was the proceeds of drug trafficking or other organized criminality such as counterfeiting fashion accessories. Figueira’s network was also used to launder the proceeds of non-illicit commercial activity, where the purpose of laundering was to evade sanctions on Venezuela.

Figueira was reluctant to receive cash in the United States due to the regulatory and law enforcement attention this would attract, whereas in cash-focused economies such as Venezuela, the cash could be more easily introduced into the financial system.

Where cash was collected by Figueira’s affiliates in U.S. locations, he charged higher fees to reflect the greater risks involved. U.S. cash deposits included revenues from:

Proceeds from selling counterfeit wallets in Miami, Florida
Proceeds from “white” sales, which is a reference to drug proceeds, in the Washington, DC area

Step 2: Cash to Crypto

The cash was converted into crypto, specifically Tether (USDT) on the Tron blockchain. USDT is a stablecoin, meaning it is “pegged” to the U.S. dollar, and is less volatile in value than assets such as Bitcoin or Ethereum. USDT is also the stablecoin with the highest trading volumes of more than $100 billion every 24 hours and the highest market capitalization of more than $183 billion, which provides significant liquidity.

Transaction (“gas”) fees on the Tron blockchain are usually lower than other blockchains such as Ethereum. This is noteworthy because where crypto is going to be “layered” through multiple transactions (Step 3) in an attempt to obscure its illicit origin, each movement incurs a cost. Using blockchains with lower gas fees minimizes laundering costs.

“It [USDT] is used to transfer money in a quick way, even to make it get to jurisdictions that have some type of issues, etcetera. For example, to send it to China. It is not that easy to pay in China. Or, let’s say it because I’m from there, to bring resources from Venezuela, and to pay different accounts not only in the United States but also in other parts of Europe and Asia, through USDT, because Venezuela doesn’t have the liberty to interact with the international financial institutions because of the sanctions.” – Jorge Figueira recorded in an FBI audio recording, translated from Spanish

Step 3: Crypto Layering

The USDT was moved through multiple crypto wallets, comparable with layering fiat currency. Since each movement on the blockchain incurs gas fee costs, legitimate activity minimizes the number of movements, whereas willingness to incur these costs is indicative of illicit activity to obscure the origin of the crypto.

On average, Figueira layered crypto through 4 to 9 transactions over short periods. Examples included:

Transaction 4: 5 x crypto transactions in 1 hour 10 mins
Transaction 5: 4 x crypto transactions in 1 hour 32 mins
Transaction 6: 9 x crypto transactions in 22 mins

After layering, the crypto arrived in a wallet referred to by Figueira as his “macro-wallet.” The macro-wallet aggregated multiple layered flows. It received a total of 1,056,755,688.677986 USDT and sent 1,056,755,688.677986 USDT. The equivalence between the inflows and outflows are consistent with the wallet being used to “pool” crypto before onward movement.

Source: Elliptic

Step 4: Offramp Using OTC Brokerages and Shell Company Bank Accounts

Figueira off-ramped the crypto back into fiat currency such as U.S. dollars using “liquidity providers” and shell companies.

The liquidity providers were OTC brokerages that facilitate trading directly between counterparties, usually to facilitate high value trades without causing the price slippage or volatility that could occur if they are traded on an exchange.

In the indictment, Figueira refers to using liquidity providers including OTC brokerages “Enigma, Anchorage, Abra” and others. Enigma, Anchorage, and Abra are regulated/registered in the United Kingdom or United States – though the indictment does not establish whether Figueira’s statements have been verified.

Figueira operated at least four shell companies to receive the conversion of crypto into fiat currency. At least one (“Company A”) was physically located in the United States, in Sunny Isles Beach, Florida.

“I can’t go and tell them [banks] that I am a money transmitter because they would close the doors for me immediately. So, I tell them that we are a credit company… that is what we do publicly, we are a credit company…” – Jorge Figueira recorded in an FBI audio recording, translated from Spanish

Figueira described how he adapted the information he presented to financial institutions that provided bank services to the shell companies to minimize detection.

He intentionally avoided describing the businesses as money transmitters because this would attract scrutiny from banks. Instead, he described Company C as a “credit company” and another of the shell companies a “trade financing consulting company.”
He created websites with the specific intention of meeting bank due diligence requirements, despite the company not actually being a legitimate business.

“I don’t have personnel here [the business address in Florida] entering operations or entering data in the computers, receiving money, nothing… We created some webpages because it is mandatory for the banks here.” – Jorge Figueira recorded in an FBI audio recording, translated from Spanish

The FBI assessed that the companies were shell companies used for illicit purposes:

One had a website but Figueira stated the business did not have “personnel or operations”
There were no legitimate transactions (such as payroll) in the company’s transactional activity.
There were rapid inflows into the accounts managed by Figuera, primarily from crypto platforms.
There were rapid outflows to high risk jurisdictions Colombia, China, Panama, and Mexico.
The volumes of inflows and outflows were extremely high, for example over the two-year period from July 2023 – July 2025, approximately $2.8 billion was moved through the accounts.

Red Flags & Risk Indicators

Financial institutions and crypto businesses should be alert to these red flags and should integrate them into their KYC/CDD, transaction monitoring, and investigations processes, taking appropriate action as required.

Shell Company Red Flags

🚩 Companies do not appear to have staff or operations, even if they have a website.

🚩 Transactions do not include legitimate business activity e.g. there are no payroll or business expenses.

🚩 The business is described as operating in a “finance-adjacent” sector such as trade finance consulting or credit.

Transactional Red Flags

🚩 There are indicators of pooling and/or funneling, for example the inflows are equivalent to outflows, especially where there are high value/volume/velocity flows over short periods.

🚩 Inflows and/or outflows are not consistent with the business type or involve higher risk products (such as crypto) or jurisdictions.

🚩 Crypto transactions involve multiple movements, in the absence of a business rationale.

Crypto businesses should already apply blockchain investigations and screening as part of their risk management programs, both at onboarding and throughout the client lifecycle, to identify indicators of high risk activity.

Traditional financial institutions should take action too: cases like Figueira demonstrate that professional money launderers continue to use the financial system as part of their laundering methodology, and these institutions may be a detection point into a wider laundering scheme.

These institutions should extend their financial crime compliance programs to include crypto measures – even if they do not directly service crypto clients or offer crypto products and services. In addition to red flags for shell companies or unusual transactional activity, where there are red flags for higher-risk crypto activity, like those above, the institution should consider crypto-specific enhanced due diligence. This may include requesting additional disclosure from the client about their crypto brokerage or exchange accounts or wallet addresses. The financial institution can then use blockchain analytics to conduct a more detailed assessment on whether there are further higher-risk activities.

Author

Catherine M. Woods is an Associate Managing Director at the Institute for Financial Integrity where she leads initiatives on countering cartels and Chinese Money Laundering Networks, illicit procurement networks and export controls, and emerging technologies including digital assets. For more information about our products and services, please contact info@finintegrity.org.

Upcoming Webinar

Join us for a webinar exploring what recent enforcement actions against banks, fintechs, crypto businesses, and casinos reveal about how illicit actors exploit the financial system and how regulators assess AML/CFT and sanctions compliance programs.

View Agenda and Register

Recommended Blogs

KYC Is Not Just Onboarding, It’s a Living Risk Assessment

March 11, 2026

When customer profiles become outdated or incomplete, the controls that rely on them, including transaction monitoring and investigations, begin to weaken. This article explores why effective KYC programs must extend beyond onboarding and how stronger customer due diligence supports more accurate risk assessments and more effective financial crime controls.

Compliance Training as a Strategic Control

March 5, 2026

When training reflects how an institution actually operates, its value extends beyond compliance. This article examines the business case for custom compliance training and why it plays a critical role in managing risk and protecting institutional credibility.

What Effective Compliance Training Looks Like

February 25, 2026

Custom compliance training is often misunderstood as light tailoring. This article explains what real customization looks like in practice, from risk-aligned content and role-specific learning to training built around real decisions, controls, and regulatory expectations.

Why and How Standardized Training Falls Short

February 18, 2026

Today’s financial institutions operate across different products, jurisdictions, and threat environments. This article examines why standardized training falls short and where generic programs consistently break down in practice.

Wynn or Lose

February 11, 2026

Casinos have long been associated with money laundering and organized crime. Explore the recent Wynn Las Vegas $130 million forfeiture as a case study, including threats such as Chinese Money Laundering Networks, mirror transfers, proxy gambling, and the use of shell companies.

Electronic Fund Transfer Consumer Protection

February 5, 2026

The Electronic Fund Transfer Act (EFTA) was established to protect consumers using electronic fund transfers. Explore what is considered in scope and the changes proposed to include crypto.

Following the Illicit Funds

January 28, 2026

As crypto grows, so does regulatory oversight. From SARs and CTRs to MSB registration and potential FBAR requirements, crypto businesses are now firmly within the scope of financial regulations.

Blind Spots in the System

January 21, 2026

When transaction monitoring fails, the cost goes far beyond fines. This article explores why many programs still miss critical red flags and how effective training helps teams to strengthen detection, calibration, and oversight where it matters most.

Top 10: Cartel Finance & Chinese Money Laundering Networks

January 15, 2026

The Institute for Financial Integrity has identified the “Top 10” list of actionable resources for financial institutions to use to detect and respond to cartel finance and CMLNs. These can inform policies, processes, systems, controls, and training programs.