Irazmar Carbajal De Jesus, a 60-year-old Uruguayan national, has pleaded guilty in the United States to conspiring to operate an unlicensed money transmitting business.
According to the Department of Justice, the scheme involved moving funds linked to a sanctioned person from the Venezuelan government into the U.S. financial system.
The case, brought in the Southern District of Florida, highlights the compliance and financial crime risks businesses face when funds linked to sanctioned parties enter the U.S. financial system, including sanctions evasion risk and the use of unlicensed money transmitting channels.
What Happened
According to the Department of Justice, Carbajal agreed to facilitate the transfer of approximately $99,500 in cash from the Dominican Republic into a bank account in Fort Lauderdale, Florida.
The funds were described to his associate as belonging to a sanctioned person from the Venezuelan government who required assistance moving money into the United States.
Carbajal and his partner agreed to carry out the transfer for a 20 percent fee. The arrangement involved creating false invoices to justify the transactions to financial institutions and using multiple bank accounts to transmit the funds.
He also referred to the funds using coded language, describing them as a “boy who needs to be taken to school,” according to court documents cited by the Department of Justice.
The conduct formed part of an agreement to use an unlicensed money services business to move funds into the U.S. financial system.
The Government’s Case and Legal Exposure
The Department of Justice presented the case as a deliberate effort to move funds associated with a sanctioned individual through the U.S. financial system by bypassing regulatory controls.
According to the government, the use of false invoices, multiple accounts and informal transfer mechanisms was intended to disguise the nature and origin of the funds and facilitate sanctions evasion through an unlicensed channel.
Carbajal pleaded guilty to conspiracy to operate an unlicensed money transmitting business. The offence carries a maximum statutory penalty of five years’ imprisonment.
Sentencing is scheduled for 12 June 2026. A federal district court judge will determine the sentence after considering the U.S. Sentencing Guidelines and other statutory factors.
The case was investigated by the FBI’s International Corruption Unit in Miami and prosecuted by the Criminal Division’s Money Laundering, Narcotics and Forfeiture Section alongside the U.S. Attorney’s Office for the Southern District of Florida.
No restitution or forfeiture details were specified in the Department of Justice release.
Why This Matters for Business
For businesses, the case illustrates how sanctions risk, third-party exposure and weak financial controls can converge in routine cross-border payment activity.
The relatively modest value of the transfer—just under $100,000—demonstrates that enforcement risk is not limited to large or complex schemes. Even smaller transactions can lead to criminal liability where funds are linked to sanctioned individuals.
Reliance on intermediary structures presents a clear risk. Organisations that use external agents, consultants or payment facilitators must ensure those parties operate within regulated frameworks and are subject to appropriate due diligence.
It also highlights the importance of licensing and regulatory status in financial activity.
Operating outside authorised money transmission systems removes key safeguards, including reporting obligations and transaction monitoring, increasing exposure for all parties involved.
Fabricated invoices point to a core internal control weakness. Where documentation and verification processes are not robust, improper transactions can be presented as legitimate.
Behavioural indicators—such as coded language and the use of multiple accounts—remain important.
While often associated with individual misconduct, similar patterns can arise in corporate environments and should be captured through monitoring and escalation procedures.
The case also reinforces that individuals involved in facilitating financial flows can face direct criminal liability, a key consideration for executives and employees operating in cross-border financial roles.
Enforcement Context and Case Progression
The case reflects a federal enforcement action by the Department of Justice targeting the movement of funds through the U.S. financial system where those funds are linked to sanctioned individuals and facilitated through unlicensed channels.
The involvement of the Criminal Division’s Money Laundering, Narcotics and Forfeiture Section and the FBI’s International Corruption Unit indicates a focus on cross-border financial activity and the use of informal mechanisms to access the U.S. banking system.
The Department of Justice release does not indicate any broader enforcement trend beyond the facts of this case.
Carbajal is scheduled to be sentenced on 12 June 2026. No further proceedings or related investigations were specified in the Department of Justice announcement.
Case details
- Court: Not specified in the DOJ release
- District: Southern District of Florida
- Case posture: Guilty plea
- Lead investigative agency: FBI International Corruption Unit (Miami)
- DOJ components: Criminal Division (Money Laundering, Narcotics and Forfeiture Section); U.S. Attorney’s Office for the Southern District of Florida
- Date of announcement: 24 March 2026