UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 20-CR-20163-SCOLA

UNITED STATES OF AMERICA

vs. REDACTED

CARLOS ENRIQUE URBANO FERMIN, 

Defendant.

 /

FACTUAL PROFFER

The United States and Carlos Enrique Urbano Fermin (the “defendant”) stipulate and agree 

that the information herein is true and accurate, and a sufficient basis for the defendant’s plea of 

guilty, and if this case had proceeded to trial, the United States would have proven the following 

facts beyond a reasonable doubt, which prove that the defendant is guilty of Count 1 of the 

Information, Conspiracy to Commit an Offense against the United States, in violation of Title 18, 

United States Code, Section 371. 

The defendant controlled several companies, with others, including CEUF Corporation 

Limited S.A. and Constructora Urbano Fermin C.A. (together, the “Urbano Fermin Companies”). 

The Urbano Fermin Companies maintained corporate bank accounts in Panama and in South 

Florida. 

From at least as early as 2012, and continuing through at least 2016 (the “relevant period”), 

the Urbano Fermin Companies obtained numerous large contracts with joint venture subsidiaries 

of Petróleos de Venezuela S.A. (“PDVSA”) in the oil-rich Orinoco region. Specifically, the 

Urbano Fermin Companies obtained contracts with the following PDVSA subsidiaries: 

(a) Petrolera Sinovensa, S.A., a joint venture with a Chinese oil company; (b) PetroMiranda, S.A., 

Case 1:20-cr-20163-RNS Document 13 Entered on FLSD Docket 04/19/2021 Page 1 of 3
3

a joint venture with a Russian oil company; and (c) Petrocedeño, S.A. (“Petrocedeño”), a joint 

venture with two European oil companies (together, the “PDVSA Subsidiaries”). PDVSA and 

the PDVSA Subsidiaries were controlled by the Venezuelan government and performed 

government functions for and on behalf of Venezuela. 

[CONFIDENTIAL PARAGRAPH 1]

[CONFIDENTIAL PARAGRAPH 2]

The Venezuelan prosecutor’s office had an investigation into corruption in the awarding 

and paying of contracts with the PDVSA joint ventures in the Orinoco belt beginning in at least 

early 2017. At the time, Venezuelan Official 1 was a high-ranking prosecutor in Venezuela. In 

or around early 2017, the defendant met with Intermediary 1, a lawyer in Venezuela with a very 

close relationship to Venezuelan Official 1. Intermediary 1 advised the defendant that he had the 

ability to prevent criminal charges against the Urbano Fermin Companies. Intermediary 1

described himself as the “insurance” policy for the Urbano Fermin Companies against such

charges. The defendant understood that Intermediary 1 had an improper and corrupt arrangement 

with Venezuelan Official 1 that would provide protection for the Urbano Fermin Companies from 

prosecution. Based on that understanding, the defendant caused approximately $1 million in wire 

transfers from the United States to pay bribes for the benefit of Venezuelan Official 1 throguh

Intermediary 1, including on or about April 13, 2017, a transfer of approximately $100,000 from 

an account of the defendant in the United States to an account for the benefit of Intermediary 1 at 

a bank in Coral Gables, Florida. During the time Venezuelan Official 1 served as a high-ranking 

prosecutor in Venezuela, the Venezuelan government did not bring criminal charges against the 

Urbano Fermin Companies. 

Case 1:20-cr-20163-RNS Document 13 Entered on FLSD Docket 04/19/2021 Page 2 of 3
Case 1:20-cr-20163-RNS Document 13 Entered on FLSD Docket 04/19/2021 Page 3 of 3