Green and White Money: An Analysis of the Figueira Professional Crypto Laundering and Sanctions Evasion Indictment

By Catherine M. Woods

Catherine M. Woods is a Network of Experts Member at the Global Initiative Against Transnational Organized Crime (GI-TOC). Based in Washington, DC, she has held senior and specialist positions in global banking, fintech, and crypto, delivering outcomes in financial intelligence and public-private partnerships. She is also a 2026 Nonresident Fellow with the Irregular Warfare Initiative, a 501(c)3 partnered with Princeton’s Empirical Studies of Conflict Project and the Modern War Institute at West Point.

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In January 2026, Venezuelan national Jorge Figueira was indicted for laundering almost $1 billion from sanctions evasion and criminal activity over the period January 2024 to November 2025. Using a combination of cash deposits, crypto layering, brokerages, and shell companies, he operated a highly effective global laundering pipeline, informed by his expert knowledge of regulations, bank due diligence, and blockchain analytics.

For financial institutions, law enforcement, and the intelligence community, the indictment serves as a warning shot that they face skilled and capable professional adversaries – and that they need to strengthen their client risk assessment, due diligence, and ongoing monitoring accordingly.

Drivers of Demand for Professional Laundering: Geoeconomics

Illicit financial activity including drug trafficking, human trafficking, and terrorist financing, is estimated at $4.4 trillion annually, generating illicit proceeds which require laundering. Additionally, tools of economic statecraft that limit access to the legitimate financial system, such as economic sanctions and capital restrictions, can have the unintended effect of driving capital flows towards opaque and illicit channels. Unable to use the financial system to move funds or exchange currencies, they drive demand – and scale – towards professional launderers.

As an example, Chinese Money Laundering Networks (CMLNs) launder the proceeds of multiple types of criminality – but also fulfill the demand from Chinese nationals for assets outside China. With the government imposing restrictions on movement of capital to the equivalent of $50,000 per person per year, Chinese nationals turn to CMLNs to facilitate exchange of RMB for USD and other currencies. Although the funds originating in China are not criminal proceeds, CMLNs meet this demand by sourcing USD from cartels laundering illicit funds. The result is that restrictions on access to legitimate foreign exchange enable and drive criminal operations. Indicative of the scale, $312 billion in suspicious activity potentially linked with CMLNs was reported to FinCEN by U.S. financial institutions from 2020-2024.

For countries like Venezuela – which until 2026 was subject to extensive sectoral sanctions covering industries like oil and gas, petrochemicals, and shipping – financial flows are concentrated towards crypto and cash. Professional launderers and sanctions evaders increasingly select stablecoins like Tether (USDT), where the value is “pegged” to the USD. This is advantageous compared with the price volatility of assets like Bitcoin.

In Venezuela, 80% of oil revenues were paid in stablecoins like USDT, which were then distributed through the economy. Without a legitimate means to bank and use these funds, and a desire for more “secure” currencies such as the USD, a market opportunity was created for money launderers.

In summary, then, the demand for professional laundering is driven from three sources: laundering the proceeds of crime;  moving funds to evade sanctions; and moving funds to circumvent capital controls or other restrictions. Together, they generate immense illicit flows that drive scale and demand for laundering networks.

This is well-understood by professional launderers like Figueira:

“Venezuela doesn't have the liberty to interact with the international financial institutions because of the sanctions… In Venezuela, three interesting things happen . One, I receive cash that can come from the sales of refrigerators and washing machines. But [two] at the same time the cash can come from oil sales. And it is forbidden that an American company do it [trade] with Venezuela because there could be sanctions. But three it could be from the narcotraffic also. All of that comes in the same box…” – Figueira, in recorded conversations translated from Spanish by the FBI

Figueira refers to the origins of funds to be laundered as “green” and “white” money. “Green” refers to “commercial stuff” like “commercial operation[s] at the port” whereas “white” refers to the proceeds of trafficking narcotics like cocaine. Figueira applied different laundering channels depending on the source of the funds, aiming to ensure “white” money did not have a nexus with the United States.

The Figueira Capital Pipeline

In the indictment, Figueira describes his laundering networks as operating globally including in Venezuela, Panama, Argentina, Colombia, the United States, China, Dubai, Spain, and Germany. The scale of his network is significant: a “macro-wallet” used to consolidate crypto during the laundering process received and sent more than $1 billion in USDT, and Figueira stated that he could “move $100,000,000 in one transfer.” To launder such large volumes of funds, Figueira used an efficient multi-step process.

1. Deposit cash

Figueira accepted cash, which he deposited into bank accounts in Venezuela and Panama. He assessed that cash could be readily accepted in these countries without attracting undue attention from banks because they were cash-based economies.

“In Venezuela, everything gets mixed. All those dollars coming from commerce that the government of Chavez has caused all those transactions to be done in cash for different reasons, get mixed with all those dollars in cash that have questionable origin…” – Figueira, in recorded conversations translated from Spanish by the FBI

In contrast, Figueira did not accept cash in the United States because it might prompt questions about its origin. However, if it was already converted into USDT, then Figueira could accept the USDT and launder it.

2. Convert cash to crypto

After depositing the cash (or receiving crypto directly), Figueira converted it into USDT on the Tron blockchain. USDT is favored by launderers because it has stable value, and the Tron blockchain has lower transaction fees than Bitcoin and Ethereum.

USDT on Tron is a public blockchain, meaning transactions between wallets are visible. Wallets can be sanctioned, similar to a bank account, or flagged as being high risk for association with illicit activity. Showing expert understanding of blockchain technology and analytics, Figueira screened wallets to ensure they didn’t have “legal issues such that they might get frozen.” He also used and understood blockchain analytics.

“I spend money on monitoring, and I have supervision and control tools. I'm not going to lie. Around $35,000 monthly, only on tools." – Figueira, in recorded conversations translated from Spanish by the FBI

3. Layer the crypto

Figueira layered the crypto through multiple transactions with the objective of obscuring the financial trail. Each movement on the blockchain incurs a fee. Legitimate users undertake few movements to minimize costs. Conversely, multiple movements are indicative of laundering, in which fees are an acceptable cost.

In the transactions reported in the indictment, Figueira moved the crypto 4 to 9 times within short periods, for example from the transactions assessed by the FBI:

• Transaction 4 moved 5 times in 1 hour 10 minutes

• Transaction 5 moved 4 times in 1 hour 32 minutes

• Transaction 6 moved 9 times within 22 minutes

These transactions, plus many others, ended up in the same wallet, which Figueira referred to as his “macro-wallet.”

4. Pool the crypto in the “macro-wallet”

Figueira’s “macro-wallet” was a key element in his laundering pipeline – and a critical vulnerability. This single wallet received 3,379 deposits and made 2,774 withdrawals, with a total of 1,056,755,688.677986 USDT received and the equivalent amount sent. The wallet rarely maintained any significant balance, which is consistent with funneling and pooling. The macro wallet was the last crypto step before Figueira converted the crypto back to fiat currency using Over-the-Counter (OTC) brokerages and shell companies.

While not all the crypto laundered through Figueira’s pipeline moved through the macro-wallet, it still represented a significant volume of more than a billion dollars in USDT. It also reveals the scale of his operations and creates the potential to use blockchain to trace upstream and downstream flows, uncovering his network. Why would an expert money launderer leave such a weak point?

One possibility is that it indicates that off-ramping from crypto to fiat currency is difficult. At the OTC brokerages used to offramp, Figueira needed to open both crypto and traditional bank accounts. The brokerages would receive crypto from Figueira’s wallets (such as the macro wallet), convert it to currencies such as USD, and deposit the fiat into his bank accounts. If it was easy to meet brokerage CDD requirements, Figueira could have used many wallets and many shell companies, which would have distributed the laundering activity and avoided revealing so much information via a single wallet. Another explanation is that Figueira operated at such scale that the macro wallet represents only a small proportion of his overall operations.

5. Convert crypto to fiat via “liquidity providers”

Figueira used “liquidity providers,” meaning Over-the-Counter (OTC) brokerages, to convert crypto into fiat currency. He stated that he used “bigger ones like Enigma, Anchorage, [and] Abra.” These are all regulated in the United States and/or United Kingdom.

The indictment and other public sources do not confirm that these exchanges were actually used. One possibility is that if Figuera used less well-known brokerages, such as Russian-linked exchanges, he may have preferred not to disclose this to clients – instead reassuring them by referring to well-known and reputable broker names, whether he used them or not.

After converting the crypto into fiat, it was deposited into shell company bank accounts operated by Figueira.

6. Wire funds from shell companies to recipients

Figueira operated a network of shell companies, of which four are specifically referenced in the indictment. At least two out of the four companies held accounts at U.S. financial institution. Shell Company A had a registered address in Sunny Isles, Florida, and a bank account at Wells Fargo. Shell Company B had a bank account at United Bank.

These shell company accounts showed no legitimate transactional activity, such as employee payroll. Instead, they showed high levels of inbound funding from crypto brokerages and exchanges, and outbound transactions to high-risk jurisdictions including Mexico, Panama, Colombia, and China. These patterns, along with the lack of legitimate activity, are red flags for shell companies and illicit activity.

Figueira explained how he described these companies to minimize attention from financial institutions. He used “finance-adjacent” business descriptions such as “credit company” or “trade finance consulting” and intentionally avoided describing the businesses as money transmitters. He also stated that he created web pages specifically to meet U.S. financial institution due diligence requirements.

Approximately $2.8 billion was processed through the shell company bank accounts from July 2023 to July 2025.

Competitor Analysis: Chinese Money Laundering Networks

“Do you know who has excellent technology tools to do money laundering? The Chinese. But we do, too.” – Figueira, in recorded conversation translated from Spanish by the FBI

Figueira specifically references CMLNs – his competition – in the indictment. He also sets out the fees for his laundering services, which are calculated based on risk and cost.

• Crypto to shell companies in the United States: fees up to 1.5% (variable based on blockchain/brokerage fees) plus bank fees for wire transfers (an example from the indictment is $55)

• Cash deposits in Panama to a shell company in Florida: 3.5%

• Cash deposits in the United States to shell companies: 10% – although Figueira did not directly accept the cash, others could do this and Figueira could launder the proceeds once they were converted into crypto.

  
  

As a comparison, CMLNs’ primary clients are Chinese nationals seeking to move funds out of China to buy USD. CLMNs gain a second revenue source by charging fees to cartels to launder their USD (which CMLNs then sell to the Chinese nationals).

• Fees for Chinese nationals: 10%

• Fees for cartels: 2% or less

Based on this analysis, Figueira’s fees are on average slightly higher at 1.5-3.5% compared with the 2% or less charged by CMLNs to cartels, fees which are “subsidized” by the 10% fees charged to Chinese nationals.

The success of Figueira’s operations – billions of dollars over just a few years – indicates that illicit volumes are so high that there is room for multiple professional launderers to operate successfully. Additionally, as a Venezuelan national, Figueira’s expert knowledge of that economy and sanctions evasion may have given him a strategic advantage there compared with CMLNs.

Key Insights and Actions to Take

The most significant outcome of the Figueira indictment is to highlight the expert knowledge held by professional launderers. Figueira understood where cash deposits could be made while minimizing attention. He understood blockchain technology and how to use analytics to screen wallets to minimize risk of compromise. He knew how to describe his shell companies to avoid them being categorized as high risk during due diligence, by avoiding descriptions like “money transmitter.” He also knew how to develop supporting information, like websites, to make shell companies appear more legitimate. Combining these skills, he laundered potentially billions of dollars. Financial institutions and crypto businesses like brokerages would be well-advised to strengthen their controls to counter these highly capable adversaries.

But the indictment also reveals positives for financial institutions and law enforcement. Although Figueira used crypto for layering and laundering, financial institutions were often used for on-ramping and off-ramping. This reveals that while launderers and sanctions evaders may use crypto, they don’t actually want to hold crypto – they still prefer traditional fiat currencies. This provides a foothold for intervention: banks and brokerages are still targeted in the laundering and sanctions evasion pipelines, and their vigilance can uncover illicit networks.

For government, close consideration should be given to the effects of economic sanctions and other tools of statecraft. In some situations, sanctions achieve the intended outcomes. In others, they drive value outside the traditional financial system, creating demand and delivering scale to professional launderers. An alternative could be to build capacity in the financial sector of vulnerable countries: by better understanding red flags of illicit activity and effective countermeasures, financial institutions could close the weak points in their financial system – while also providing legitimate channels for financial activity. This would degrade the competitiveness of launderers by reducing demand for their services, while also increasing the cost of operating laundering networks by strengthening due diligence and monitoring.

Financial institutions and the financial system remain critical infrastructure. Professional launderers facilitate sanctions evasion, launder criminal proceeds, and enable capital flight, moving immense sums through global networks. Unified and integrated action is necessary for an effective response. For banks and brokerages, sanctions and financial crimes teams must work closely together, ensuring that end-to-end processes effectively identify unusual and suspicious activity, which may co-mingle sanctions evasion and money laundering. For government, close partnership with financial institutions is required to ensure that policies and strategies have the intended effects when they intersect with the financial system, or that informed trade-offs are made.

More broadly, the Figueira indictment demonstrates how sustained geopolitical pressure can reshape global financial flows in ways that deliver finance and footholds to illicit actors and adversarial influences – and the chokepoints where intervention can be most effective.

(All information in this article is sourced from indictment Case No. 1:25-mj-730, unless an alternative source is specified. A criminal complaint is merely an accusation. The defendant is presumed innocent until proven guilty.)