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 | Enforcement Action Dataset

Stanford Foreign Corrupt Practices Act Clearinghouse a Collaboration with Sullivan & Cromwell LLP

Enforcement Action Dataset

 
United States of America v. Gustavo Trujillo · Multiple Parties' Involvement in the Ecuadorian Oil Industry

Case Information

United States of America v. Gustavo Trujillo

Related FCPA Matter:   Multiple Parties' Involvement in the Ecuadorian Oil Industry Information

Case Information

Initiation Date:    04/04/2019  Information

Prosecuting Agency:    U.S. Department of Justice

Type of Action:    DOJ Criminal Proceeding

Docket or Case Number:    19-cr-00134

Court:    E.D. New York

Name of Prosecuting Attorneys:   

  • Richard P. Donoghue, United States Attorney
  • Robert A. Zink, Acting Chief, Fraud Section, Criminal Division
  • Deborah L. Connor, Chief, Money Laundering and Asset Recovery Section, Criminal Division
  • Mary Ann McCarthy, Trial Attorney, Money Laundering & Asset Recovery Section, Criminal Division
  • Andrey Spektor, Assistant United States Attorney
  • David Norwich Gopstein, Assistant United States Attorney
  • Matthew S. Miller, Assistant United States Attorney

US Assisting Agencies:   Unknown

Foreign Enforcement Action/Investigation:   Unknown

Foreign Assisting Agencies:   Unknown

Origin of the Proceeding:    Unknown

Whistleblower:    Unknown

Case Status:    Ongoing


Summary  Information

Gustavo Trujillo was an Ecuadorian citizen who resided in Florida since approximately May 2018. He was employed in operations and comptroller positions in the Ecuadorian office of a U.S. financial services firm for most of the period between 2005 and 2017.

According to the documents in this case, between 2013 and 2016, GalileoEnergy S.A. ("Galileo"), which was owned and controlled by Trujillo's alleged co-conspirator Ramiro Andres Luque Flores, paid bribes to officials at Ecuador's state-owned oil company Empresa Publica de Hidrocarhuros del Ecuador ("PetroEcuador") in order to obtain several contracts with PetroEcuador. The bribes were routed through intermediary shell companies and bank accounts, and in all, PetroEcuador paid Galileo approximately $27.8 million into bank accounts after which the funds were transferred back into various offshore shell company accounts that were beneficially owned and controlled by PetroEcuador officials.

On April 4, 2019, the DOJ filed a two count Information in the Eastern District of New York against Trujillo alleging conspiracy to commit wire fraud and to commit money laundering. Trujillo pled guilty on the same date, but the details of any plea agreement are not known. Trujillo was scheduled to be sentenced on June 12, 2025, but the sentencing has been adjourned with no new date set.

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