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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA

CASE NO.:

UNITED STATES OF AMERICA,

Plaintiff,

vs.

REAL PROPERTY LOCATED AT 

900 BISCAYNE BLVD UNIT #6107,

MIAMI, FLORIDA 33132,

Defendant In Rem.

_______________________________________/

VERIFIED COMPLAINT FOR FORFEITURE IN REM

The United States of America by its attorneys, Woo S. Lee, Teresa C. Turner-Jones, and 

Shai D. Bronshtein, Criminal Division, United States Department of Justice, and Adrienne E. 

Rosen, United States Attorney’s Office for the Southern District of Florida, and in accordance with 

Rule G of the Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions, 

brings this complaint for forfeiture in rem and alleges the following:

NATURE OF THE ACTION

1. This is a civil action in rem to forfeit assets involved in and traceable to an 

international conspiracy to launder money embezzled from Société Nationale des Pétroles du 

Congo, the state-owned oil company of the Republic of the Congo (“Congo”). 

2. The embezzled funds were used to purchase real property located in the Southern 

District of Florida, namely, real property located in a condominium residence at 900 Biscayne 

Boulevard, Unit #6107, Miami, Florida 33132 (the “Miami Property” or the “Defendant Asset”). 

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3. The United States seeks forfeiture of the Defendant Asset pursuant to 18 U.S.C. 

§ 981(a)(1)(C), because the funds used to acquire and maintain it are traceable to violations of U.S. 

law and specified unlawful activity.

4. The United States also seeks forfeiture of the Defendant Asset pursuant to 18 

U.S.C. § 981(a)(1)(A), because it was involved in one or more money laundering offenses in 

violation of 18 U.S.C. §§ 1956 and 1957. 

JURISDICTION AND VENUE

5. This Court has jurisdiction over this action pursuant to 28 U.S.C. §§ 1345 and 1355.

6. Venue lies in this district pursuant to 28 U.S.C. §§ 1355(b)(1)(A) and 1355(b)(2),

because acts and omissions giving rise to the forfeiture took place in the Southern District of 

Florida.

7. Venue also lies in this district pursuant to 28 U.S.C. § 1395(b), because the 

Defendant Asset is located in the Southern District of Florida.

PEOPLE AND ENTITIES

8. The Plaintiff is the United States of America. 

9. The Defendant Asset consists of real property located in a single-story

condominium residence at 900 Biscayne Boulevard, Unit #6107, Miami, Florida 33132.

10. Société Nationale des Pétroles du Congo (“SNPC”) is a state-owned oil company 

in the Republic of the Congo. The company manages the Congolese government’s shares of oil 

production in Congo.

11. Denis Sassou Nguesso (“President Nguesso”) is the president of the Republic of 

Congo. He became president in 1979, following a series of coups, and has held that office for 

approximately 35 of the last 40 years. 

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12. Denis-Christel Sassou Nguesso (“Minister Nguesso”) is President Nguesso’s son. 

He is a minister of parliament in Congo—in 2017, he won reelection with 99% of the vote—and

has held a number of important positions at SNPC. From 2001-2009, Minister Nguesso was the 

head of various SNPC departments. In 2010, he was appointed—by his father, President 

Nguesso—to serve as SNPC’s “Directeur Général Adjoint en charge de l’Aval Pétrolier,” Deputy 

Director-General of Downstream Operations, commonly abbreviated as “DGA.” As DGA, 

Minister Nguesso was responsible for the processing, refinement, and sale of oil extracted in 

Congo. That position gave him enormous control over SNPC’s activities, and, critically, its 

finances. Minister Nguesso and his family members, including his father, President Nguesso, have 

been investigated for (and several have been charged with) corruption, money laundering, and 

related crimes around the world. For instance, French authorities in 2015 seized a luxury property 

in Paris acquired by the Nguesso family. In 2019, San Merino authorities seized a bank account 

containing approximately €19 million allegedly deposited by President Nguesso. 

13. Associate A, a U.S. resident, is the son of a former Gabonese government official 

and a longtime associate of Minister Nguesso. Since at least 2009, Associate A helped Minister 

Nguesso transfer money into the United States and purchase and maintain assets in the United 

States, including within the Southern District of Florida.

14. Danielle Ognanosso is Minister Nguesso’s first wife.

15. Nathalie Bumba-Pembe is Minister Nguesso’s second wife and an authorized user 

of the Miami Property. 

16. The interests of Denis-Christel Sassou Nguesso and Nathalie Bumba-Pembe may 

be adversely affected by these proceedings. 

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FACTUAL ALLEGATIONS

17. Between 2011 and 2014, Minister Nguesso embezzled millions of dollars from 

state-owned SNPC. He funneled the misappropriated funds into accounts in the names of his 

various shell companies, including Mercuria, Atlas Logistique and SCI Etoile, at the Congo 

subsidiary of BGFI Bank Group S.A. (“BGFI”), a Gabon-based bank.

18. He then used a network of bank accounts in the names of shell companies and 

nominees to attempt to conceal the money he misappropriated from SNPC and to acquire assets, 

including the Miami Property. 

19. Between April 30, 2009 and April 22, 2016, Minister Nguesso transferred 

approximately $10.3 million to bank accounts opened by Associate A in the Southern District of 

Florida. Associate A, at Minister Nguesso’s direction, then used the stolen funds to acquire real 

estate and luxury goods for Minister Nguesso and his wives, including the Miami Property. Once 

he had acquired the properties for Minister Nguesso, Associate A used additional stolen funds to 

cover expenses related to these properties, including property taxes, condo fees, and maintenance

expenses.

I. Minister Nguesso Was The Gatekeeper To Congo’s Oil Wealth

20. Congo is one of the largest petroleum producers in central Africa. As of 2017,

Congo produced 291,000 barrels of crude oil per day. From 2012-2016, it produced, on average,

approximately 94 million barrels per year, which, based on inflation-adjusted prices, translates to

almost $7 billion in revenue each year.

21. Congo exports the majority of its oil to foreign states, including to China, the 

European Union, and the United States. Petroleum products accounted for 90 percent of Congo’s 

export revenue over the past decade.

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22. The Congolese government heavily taxes oil production. In 2013 alone, it received 

roughly $5 billion in taxes on oil extraction. 

23. The petroleum sector in Congo is strictly controlled. Licenses for petroleum 

exploration are limited, and foreign companies are required to enter into production sharing 

agreements that grant shares in their ventures to the Congolese government. In 2015, Congo 

enacted its Hydrocarbon Law that required oil companies to provide the Congolese government 

with at least 35% of the revenue from any oil extracted in Congo.

24. SNPC, as a state-owned institution, effectively controls the Congolese petroleum 

sector on behalf of the government. SNPC holds exclusive authority to issue oil and gas extraction 

licenses. And, by law, SNPC owns a 15 percent stake in all of the country’s oil fields, and must 

be given at least a 15 percent share in any joint oil exploration and production venture. SNPC’s 

upper management is appointed by the government, with President Nguesso having ultimate 

control.

25. Over the past two decades, Minister Nguesso expanded his control over SNPC, and, 

by extension, the Congolese petroleum industry. Minister Nguesso began his career at SNPC in 

2001 as an executive in the company’s London and Brazzaville trading branches. In 2005, he 

became the managing director of one of SNPC’s five subsidiaries. And in 2010, Minister Nguesso

was appointed by his father, President Nguesso, as the DGA responsible for all of SNPC’s 

downstream operations, General Manager of the state owned refinery, and Chief Executive Officer 

of SNPC-Distribution. Those positions put him in charge of SNPC’s operations, and gave him 

broad access to the company’s finances.

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II. Minister Nguesso Abused His Position At SNPC To Misappropriate Public Funds

26. Minister Nguesso used his control over the Congolese oil sector to embezzle 

millions of dollars in public funds from SNPC and extract millions more in bribes.

A. Minister Nguesso Misappropriated Money from SNPC.

27. Minister Nguesso enriched himself directly from Congo’s oil wealth. Beginning in 

at least 2011, Minister Nguesso diverted revenue from SNPC and funds maintained in other state 

accounts into shell company accounts that he owned. As an SNPC executive, minister, and son of 

the president, Minister Nguesso was able to simply direct BGFI Bank to transfer SNPC’s (and 

other public) funds to his own accounts. He did so many times.

28. The primary destination of the funds was an account at BGFI Bank in Congo that 

Minister Nguesso held in the name of Mercuria (the “Mercuria Account”). Mercuria was a shell 

entity that Minister Nguesso used to collect the stolen SNPC funds. He then took money from the 

Mercuria Account to finance his lavish lifestyle and acquire assets. Invoices for Minister 

Nguesso’s profligate personal spending were addressed to Mercuria.

29. Mercuria’s name resembles “Mercuria Energy Trading,” a legitimate, privatelyheld petroleum company based in Switzerland with operations in Africa. Minister Nguesso’s 

“Mercuria” has no known connection to the actual company. The Mercuria Account has no known 

connection to Mercuria Energy Trading.

30. Minister Nguesso instructed the CEO of BGFI bank in Congo to transfer money 

from SNPC’s accounts at BGFI to the Mercuria Account. For instance:

a. On September 14, 2011, Minister Nguesso emailed the BGFI CEO: “Hello 

I kindly ask you to transfer 4,070,000,000 CFA [central African currency used in Congo]

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through the special snpc account on 11-44 at profit from the mercuria account.”1 Based on 

historical exchange rates, this amounted to approximately $8.3 million.

b. In an email the next day, Minister Nguesso wrote to the BGFI CEO: “it is 

necessary to proceed to the settlement on the 02 ‘a oing’ of 44.271.385.504 CFA, and then 

transfer to the mercuria account 4.117.550.021 CFA.” That “settlement” amounted to over 

$90 million.

c. On September 16, 2011, the BGFI CEO wrote to Minister Nguesso: “the 

account Mercuria 12- 31 was credited with FCFA [the same as CFA] 5 467 661 380 the 

14/09.” That is equivalent to approximately $11 million. In the same email, Minister 

Nguesso discussed separate business matters related to SNPC. Once again, Minister 

Nguesso told the BGFI CEO to simply pass money from SNPC to his own account. 

d. Later that day, the BGFI CEO confirmed that nearly $11 million related to 

the “invoice djeno august B/1 14 August 2011 Athenian Harmony,” referencing a specific 

contract, oil concession, and petroleum ship, had been transferred successfully to Minister 

Nguesso’s personal Mercuria account. Minister Nguesso responded simply, “Ok thank 

you!” 

e. Also on September 16, 2011, Minister Nguesso directed the BGFI CEO:

“Concerning the operation of the djeno [an oil concession] (42.010.615.221cfa), it is 

necessary to pass on the snpc 02 the sum 39.646.493.921 CFA, and then to pass on the 

account mercuria 2.464.121.300 CFA.” Once again, Minister Nguesso misappropriated

funds related to oil concessions that should have gone to SNPC, and sent the equivalent of 

over $5 million to himself.

 1 Where messages involving Minister Nguesso were initially in French, they have 

been translated into English, and only the translation is included in this Complaint.

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f. On July 30, 2012, Minister Nguesso again instructed the BGFI CEO to 

transfer a portion of a payment in CFAs—roughly $1.8 million, all of which should have 

gone to SNPC—to his Mercuria account.

31. To send instructions to the BGFI CEO to transfer money from SNPC to his own 

accounts, Minister Nguesso often used a Yahoo email account, rather than an official SNPC email 

address, which helped to conceal the theft. 

32. Minister Nguesso’s movement and management of SNPC’s funds was beyond the 

scope of his job as SNPC’s DGA. Ordinarily, SNPC’s Directorate of Finance—rather than its 

DGA—dealt with SNPC’s accounting and banking relationships. 

33. In addition to the above transfers, Minister Nguesso established a host of additional 

accounts in the names of other nominees and shell companies, including Atlas Logistique and SCI 

Etoile. He then caused millions of dollars in funds to be deposited into those nominee and shell 

company accounts, and used the funds to purchase luxury goods, and to acquire assets in the U.S., 

France, and elsewhere.

B. Minister Nguesso Took Bribes and Engaged in Self-Dealing.

34. On information and belief, Minister Nguesso also accepted bribes worth over $1.5 

million in exchange for awarding lucrative oil license contracts on behalf of SNPC from 

approximately 2014-2016.

35. Further, he used his position of control at SNPC to ensure that companies he had 

an interest in were granted the status of “local partner” for lucrative oil projects. He thus 

guaranteed that a portion of Congo’s oil wealth flowed directly to him. Minister Nguesso again 

used BGFI Bank as part of that activity. 

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III. Minister Nguesso Spent Significantly More Money Than He Claimed to Earn

36. In January 2016, Minister Nguesso was questioned by CBP when he entered the 

United States. He was traveling with $100,000 in $100 bills, still shrink wrapped in plastic from 

the United States Mint. 

37. Minister Nguesso (falsely) told CBP that he did not own any property in the United 

States.

38. Minister Nguesso also told CBP that he was employed as the Deputy Manager of 

SNPC, and that he received a salary of €35,000 per month, or approximately $460,000 per year.

39. But from September 20, 2007 to January 8, 2017, Minister Nguesso spent more 

than $29 million acquiring assets and paying for his and his family’s lavish lifestyle. Each year 

from 2012 to 2016, he spent multiples of his purported annual income.

40. In Florida alone, Minister Nguesso spent more than $4.8 million acquiring two 

properties. In 2009, he purchased a property in Coral Gables for more than $2.4 million in his 

wife’s name. And in 2012, he acquired the Miami Property for approximately $2.8 million. 

41. He and his wives spent extravagantly around the world. In 2007, Minister Nguesso

and his wife spent more than €150,000 (equivalent to approximately $165,000) remodeling a

kitchen in one of their homes in France. The invoices were addressed to Mercuria.

42. Beginning in 2010, Minister Nguesso paid hundreds of thousands of dollars to a 

Geneva and Hong Kong-based aviation company for private flights for himself and his family. 

Again, the invoices were addressed to Mercuria.

43. In 2012, in addition to spending almost $3 million on the Miami property, Minister 

Nguesso paid approximately €555,098.93 or $666,000 to a Parisian kitchen designer for work 

relating to one of his Paris properties. The invoices were addressed to Mercuria.

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44. In 2013, Minister Nguesso spent €501,900 or approximately $650,000 during a stay 

at a hotel in Los Angeles. The expenses were billed to Minister Nguesso by a French firm via an 

invoice from a Hong Kong company issued to Mercuria. That same year, Minister Nguesso also 

purchased three Range Rover automobiles (which retail at over $60,000 each) with funds in the 

Mercuria Account and had the dealer invoice the transaction to Mercuria. 

45. In 2014, Minister Nguesso purchased approximately €1.4 million worth of jewelry 

for his wife in Paris. Minister Nguesso also spent approximately €110,000 to purchase a Patek 

Philippe model 5961R watch for himself in Paris. He used a bank account in the name of his 

bodyguard, Charly Gaulbert Elenga, to wire the funds, and used the name of a nominee to complete 

the purchase. In September 2014, Minister Nguesso received an invoice, again addressed to 

Mercuria, for €713,684 (approximately $788,431) for a private flight and other travel expenses he 

incurred in connection with a trip to Miami.

46. In 2015, Minister Nguesso spent €546,000 or approximately $589,000 to pay the 

fees of a Parisian architect for work relating to one of his Paris properties. The bill was made out 

to Atlas Logistique. 

47. In 2016, Minister Nguesso spent approximately $857,000 using Atlas Logistique’s 

BGFI bank account to acquire seven black Cadillac Escalades and ship them to Congo.

48. In addition to the above transactions, between 2011 and 2016, Minister Nguesso 

imported at least $3,690,447 in cash into the United States—and that’s just what he declared to 

CBP. Minister Nguesso never reported removing any currency from the United States, as he would 

have been required to do pursuant to 31 U.S.C. § 5316 had he transported more than $10,000 in 

cash out of the United States. 

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IV. Minister Nguesso Purchased The Miami Property With Funds Traceable To Funds 

He Misappropriated From SNPC

49. Minister Nguesso’s “extra” money came from the corruption, self-dealing, and theft 

from SNPC described above. He used the money he took from SNPC specifically to purchase the 

Miami Property.

50. The first step was to get the money into the United States. Beginning in at least 

2009, Minister Nguesso began wiring money from the Mercuria Account and other accounts under 

his control in the Congo to bank accounts in the United States. 

51. Minister Nguesso had opened accounts in the United States for himself. When he 

did so, he tried to disguise his ownership. He opened four accounts at Bank of America between 

2013 and 2016, for instance, using his alias, Denis Christelle.2

 When he did so, he lied about his 

job and his income. He stated that he was a “manager” for a company called “Merchurrea.” He 

also claimed falsely that his annual salary was only $50,000. Minister Nguesso never disclosed to 

Bank of America that he was a Congolese public official or that he was President Nguesso’s son. 

He took those steps in an effort to hide the source and nature of the funds that went into his 

accounts.

52. Beginning in 2011, Minister Nguesso generally did not use his own accounts, even 

in the name of an alias, to transfer the stolen funds into the United States. Instead, he almost 

always used accounts that had been opened by, and were in the name of, his associate and nominee, 

Associate A.

3

 2 Minister Nguesso used a second Congo passport under the name Denis Christelle 

to open the bank accounts and make purchases in the U.S. in an attempt to conceal his identity. 

Minister Nguesso used his actual passport when entering the country.

3 The limited exception is that Minister Nguesso did transfer funds to an account at 

Bank of America listed under his alias, Denis Christelle, to pay certain bills for the Miami Property. 

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53. Associate A had two accounts at Bank of America that Minister Nguesso used. 

From 2009 to 2016, Minister Nguesso wired, via his shell companies, over $8.9 million into 

Associate A’s Bank of America checking account, and sent over $1.5 million from his personal 

account.

54. The transfers are summarized in this table:

Wire Transfers Sent By Minister Nguesso to Associate A’s U.S. Bank Accounts

Date Source Amount 

4/30/2009 Sassou Nguesso Denis $600,000.00

5/29/2009 Sci De L'Etoile $1,892,374.45

2/9/2010 Sassou Nguesso Denis $125,275.00

6/15/2010 Sassou Nguesso Denis $330,920.00

10/15/2010 Sassou Nguesso Denis $145,000.00

10/25/2010 Sassou Nguesso Denis $250,500.00

1/26/2011 Sassou Nguesso Denis $100,000.00

7/7/2011 Elenga Charly Gaulbert $385,000.00

11/18/2011 Sci Etoile $93,000.00

2/16/2012 Mercuria $100,000.00

6/4/2012 Mercuria $105,000.00

6/5/2012 Sci Etoile $327,500.00

7/18/2012 Sci Etoile $209,500.00

8/22/2012 Mercuria $3,589,543.00

4/23/2013 Sarl Atlas Logistique $222,000.00

12/24/2013 Atlas Logistique $219,100.00

1/6/2014 Sarl Atlas Logistique $1,000,000.00

2/24/2015 Atlas Logistique $150,000.00

3/17/2015 Sarl Atlas Logistique $60,000.00

9/16/2015 Atlas Logistique $300,000.00

4/22/2016 Atlas Logistique $169,500.00

Total $10,374,212.45

55. Minister Nguesso sent the money to Associate A’s accounts in an attempt to launder 

it and conceal the source and nature of the funds. 

56. In August 2012, Minister Nguesso used some of that money to purchase the Miami 

Property, a penthouse condo with floor-to ceiling windows and a sweeping view of Miami’s 

Biscayne Bay, the Atlantic Ocean, and the Miami skyline. The condo has over 3,500 square feet 

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including three terraces, three large bedrooms, and five bathrooms. It was listed for sale at $2.4 

million.

57. To make the purchase, on August 22, 2012, Minister Nguesso transferred 

$3,589,543 from the Mercuria Account to Associate A’s Bank of America checking account in 

Miami. Before that transfer, the balance in Associate A’s Bank of America account was 

approximately $150,000. 

58. The money in the Mercuria Account had previously been stolen from SNPC. As 

noted above in Paragraph 30(f), less than a month earlier, on July 30, 2012, Minister Nguesso had 

diverted approximately $1.8 million from SNPC’s account to the Mercuria Account. 

59. For this and other transfers, Minister Nguesso directed Associate A to create 

fraudulent invoices that would explain the transfer of funds. Associate A complied, creating a 

bogus $3,589,543 invoice from an entity he controlled to Minister Nguesso for kitchen appliances 

and other expenses.

60. On September 6, 2012, Associate A transferred $50,000 of the funds to an attorney 

in Florida for the down payment for the purchase of the Miami Property. 

61. On October 3, 2012, Associate A sent $2,334,933.64 of those funds to the same 

Florida attorney to complete the acquisition. 

62. Minister Nguesso took multiple additional steps to conceal his ownership of the 

Miami Property. First, the sales contract for the Miami Property identified Associate A alone as 

the property’s purchaser. At closing, the property was recorded as belonging to Associate A and 

Denis Christelle, Minister Nguesso’s alias.

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63. Associate A’s ownership was a sham—he transferred his interest in the Miami 

Property to “Denis Christelle” the day the sale closed. Minister Nguesso and one of his wives, 

Nathalie Bumba-Pembe were listed as having access to the property from the outset.

64. Minister Nguesso had used Associate A as a front to complete the transaction and 

obscure his involvement. Minister Nguesso’s use of the Mercuria Account, rather than one in his 

own name, assisted him in concealing his identity and the nature of the stolen funds. 

65. Associate A used his identity, rather than Minister Nguesso’s, to renovate the 

Miami Property. Associate A applied for permits to renovate the apartment in his name (rather 

than Minister Nguesso’s), including in February 2013. And he signed construction contracts, 

including in December 2012. Minister Nguesso’s name (even his alias) was entirely absent from 

those records. Associate A paid for the renovations, using his Bank of America account, with

money that had originally come from the Mercuria Account. 

66. Between November 2012 and May 2013, Associate A paid $207,500 to an interior 

designer with whom both Associate A and Minister Nguesso exchanged emails concerning the 

Miami Property.

67. Associate A also paid the property taxes for the Miami Property using SNPC money 

that had been transferred to his Bank of America account via Mercuria. From 2012-2016, 

Associate A wrote checks totaling $133,144.71 with funds traceable to the Mercuria Account to 

pay taxes on the Miami Property.

68. On June 13, 2016, Minister Nguesso purchased a cashier’s check for $49,230.13 

from Bank of America to pay property taxes for the Miami Property using his alias.

69. On September 22, 2016, Minister Nguesso, again using his alias, transferred his 

interest in the Miami Property to Nathalie Bumba-Pembe, his second wife. 

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70. The transfer was not for value. Instead, Minister Nguesso’s transfer of the Miami 

Property to Nathalie Bumba-Pembe—and his use of accounts in the name of Associate A and his 

alias—was meant to conceal Minister’s Nguesso’s true ownership.

71. The foregoing actions were designed to conceal or disguise the nature, location, 

source, ownership, and control of the funds Minister Nguesso had misappropriated from SNPC

and used to acquire and maintain the Defendant Asset.

V. Minister Nguesso Purchased Other Properties Using A Similar System of 

Misdirection and Nominees

72. Minister Nguesso followed the same pattern in acquiring real property in Coral 

Gables, Florida (the “Coral Gables Property”). In 2009, he began wiring money from an account 

he controlled at BGFI Bank in the name of a shell company, SCI Etoile, to Associate A’s Bank of 

America checking account. On April 30, 2009, Minister Nguesso wired $600,000 to Associate 

A’s Bank of America account. And on May 29, 2009, he sent another $1,892,374.45. Before 

those transfers, the balance in Associate A’s accounts at Bank of America was under $130,000.

73. Minister Nguesso sought to hide his ownership and control of the Coral Gables 

Property by recording its ownership in the name of Danielle Ognanosso, the alias of his first wife, 

Danielle Ognanosso Sassou Nguesso. She was a nominee, however. She told French authorities 

in 2016 that she did not own any property in the United States. She also denied knowledge of the 

entity SCI Etoile. 

74. Minister Nguesso also directed BGFI to remove his name from a bank document 

related to the purchase. In an April 23, 2009, email to the BGFI CEO, Minister Nguesso requested

the preparation of a financial solvency letter on Ognanosso’s behalf. The next day, Minister 

Nguesso sent another email to the BGFI CEO, “It is necessary to remove from the certificate the 

mention of Sassou Nguesso; just put Mrs. Daniele Ognanosso.”

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75. Following the purchase of the Coral Gables Property, Associate A, at Minister 

Nguesso’s direction, paid for the property’s upkeep from funds that Minister Nguesso funneled 

into Associate A’s Bank of America account. 

76. Minister Nguesso also used his shell companies to pay for upkeep. For instance, 

he sent a wire for $34,000 from Atlas Logistique on April 15, 2015 to cover household expenses

relating to the Coral Gables Property.

77. Again, Minister Nguesso engaged in these transactions to hide his relation to the 

money and to conceal its source. 

78. Minister Nguesso also purchased and renovated property in France using the same 

system of shell companies and nominees to shift and hide funds. Minister Nguesso used bank 

accounts under the name of his bodyguard, Elenga, in his property dealings in France. Just as with 

the Miami Property and Coral Gables Property, Minister Nguesso did all of this to conceal the 

nature and source of the funds used to acquire the properties, as well as his ultimate ownership.

FOREIGN LAW BASIS FOR FORFEITURE

79. Misappropriation of public funds is a criminal offense under Congolese law, as 

enumerated by the Penal Code of Congo, including Articles 177 and 178. 

80. The Penal Code of Congo prohibits the misappropriation, theft, or embezzlement 

of public funds by or for the benefit of a public official. The Penal Code provides the following:

a. Article 177 prohibits government officials from “using their power of their 

ranks for corruption.” 

b. Article 178 prohibits any person from requesting or agreeing to receive 

offers or presents in order to obtain awards, positions, jobs, or favors granted by the public 

authorities, entities, or profits which abuse or influence favorable decisions.

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81. The Constitution of the Republic of Congo also prohibits corruption and further 

defines corruption under Congolese law: 

a. Article 53 of the Constitution provides: “The property of the State is sacred. 

Property in the public domain is inalienable, non-transferable, imprescriptible, and 

unseizable. Every citizen must respect and protect [the state property].”

b. Article 54 of the Constitution also provides: “Any act of sabotage, 

vandalism, corruption or squandering or denigration of public funds is prohibited and 

punished by the conditions laid down by law.”

FIRST CLAIM FOR RELIEF

18 U.S.C. § 981(a)(1)(C)

82. Paragraphs 1 through 81 above are incorporated by reference as if fully set forth 

herein.

83. The Defendant Asset is property that constitutes, or is derived from, proceeds 

traceable to a foreign offense involving the misappropriation, theft, or embezzlement of public 

funds by or for the benefit of a public official (18 U.S.C. § 1956(c)(7)(B)(iv)), and the international 

transportation or receipt of stolen or fraudulently obtained property (18 U.S.C. § 2314), which are

specified unlawful activities under 18 U.S.C. §§ 1956(c)(7)(A) and 1956(c)(7)(B)(iv), or a 

conspiracy to commit such offenses. 

84. Therefore, the Defendant Asset is subject to forfeiture to the United States pursuant 

to 18 U.S.C. § 981(a)(1)(C).

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SECOND CLAIM FOR RELIEF

18 U.S.C. § 981(a)(1)(A)

85. Paragraphs 1 through 81 above are incorporated by reference as if fully set forth 

herein.

86. The Defendant Asset is involved in, or is traceable to property involved in, a 

transaction or attempted transaction in violation of section 18 U.S.C. § 1957. Specifically, the 

Defendant Asset is involved in or is traceable to a monetary transaction in criminally derived 

property of a value greater than $10,000, that is a foreign offense involving the misappropriation, 

theft, or embezzlement of public funds by or for the benefit of a public official (18 U.S.C. § 

1956(c)(7)(B)(iv)), and the international transportation or receipt of stolen or fraudulently obtained 

property (18 U.S.C. § 2314). 

87. Accordingly, the Defendant Asset is subject to forfeiture pursuant to 18 U.S.C. § 

981(a)(1)(A). 

THIRD CLAIM FOR RELIEF

18 U.S.C. § 981(a)(1)(A)

88. Paragraphs 1 through 81 above are incorporated by reference as if fully set forth 

herein. 

89. The Defendant Asset is involved in, or is traceable to property involved in, a 

transaction or attempted transaction in violation of section 18 U.S.C. § 1956(a)(1)(B)(i). 

Specifically, the Defendant Asset is involved in or traceable to a financial transaction involving 

the proceeds of specified unlawful activities, that is a foreign offense involving the 

misappropriation, theft, or embezzlement of public funds by or for the benefit of a public official 

(18 U.S.C. § 1956(c)(7)(B)(iv)), and the international transportation or receipt of stolen or 

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fraudulently obtained property (18 U.S.C. § 2314f), and which was designed in whole or in part to 

conceal or disguise the nature, the location, the source, the ownership or the control of the proceeds 

of the specified unlawful activities in violation of 18 U.S.C. § 1956(a)(1)(B)(i). 

90. Accordingly, the Defendant Asset is subject to forfeiture pursuant to 18 U.S.C. § 

981(a)(1)(A). 

FOURTH CLAIM FOR RELIEF

18 U.S.C. § 981(a)(1)(A)

91. Paragraphs 1 through 81 above are incorporated by reference as if fully set forth 

herein.

92. The Defendant Asset is involved in, or is traceable to property involved in, a 

transaction or attempted transaction in violation of section 18 U.S.C. § 1956(a)(2)(B). 

Specifically, the Defendant Asset is, or is traceable to, funds that were, transported, transmitted, 

or transferred to a place in the United States from or through a place outside the United States, 

knowing that the funds involved in the transportation, transmission, or transfer represent the 

proceeds of some form of unlawful activity and knowing that such transportation, transmission, or 

transfer was designed in whole or in part to conceal or disguise the nature, the location, the source, 

the ownership, or the control of the proceeds of specified unlawful activities, that is a foreign 

offense involving the misappropriation, theft, or embezzlement of public funds by or for the benefit 

of a public official (18 U.S.C. § 1956(c)(7)(B)(iv)), and the international transportation or receipt 

of stolen or fraudulently obtained property (18 U.S.C. § 2314). 

93. Accordingly, the Defendant Asset is subject to forfeiture pursuant to 18 U.S.C. § 

981(a)(1)(A). 

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FIFTH CLAIM FOR RELIEF

18 U.S.C. § 981(a)(1)(A)

94. Paragraphs 1 through 81 above are incorporated by reference as if fully set forth 

herein.

95. The Defendant Asset is involved in, or is traceable to property involved in, a 

conspiracy to launder the proceeds of specified unlawful activities in violation of 18 U.S.C. 

§ 1956(h). Specifically, the Defendant Asset is involved in, or is traceable to funds that were 

involved in, a conspiracy: (1) to conduct and/or attempt to conduct financial transactions which 

involve the proceeds of specified unlawful activities, that is a foreign offense involving the 

misappropriation, theft, or embezzlement of public funds by or for the benefit of a public official 

(18 U.S.C. § 1956(c)(7)(B)(iv)), and the international transportation or receipt of stolen or 

fraudulently obtained property (18 U.S.C. § 2314); (2) to engage and/or attempt to engage in 

monetary transactions in criminally derived property of a value greater than $10,000, such property 

having been derived from specified unlawful activities, that is a foreign offense involving the 

misappropriation, theft, or embezzlement of public funds by or for the benefit of a public official 

(18 U.S.C. § 1956(c)(7)(B)(iv)), and the international transportation or receipt of stolen or 

fraudulently obtained property (18 U.S.C. § 2314), in violation of 18 U.S.C. § 1957; and (3) to 

transport, transmit, or transfer to a place in the United States from or through a place outside the 

United States, knowing that such transportation, transmission, or transfer is designed in whole or 

in part to conceal or disguise the nature, the location, the source, the ownership, or the control of 

the proceeds of specified unlawful activities, that is a foreign offense involving the 

misappropriation, theft, or embezzlement of public funds by or for the benefit of a public official 

Case 1:20-cv-22427-MGC Document 1 Entered on FLSD Docket 06/12/2020 Page 20 of 23
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(18 U.S.C. § 1956(c)(7)(B)(iv)), and the international transportation or receipt of stolen or 

fraudulently obtained property (18 U.S.C. § 2314), in violation of 18 U.S.C. § 1956(a)(2)(B)(i). 

96. Accordingly, the Defendant Asset is subject to forfeiture pursuant to 18 U.S.C. § 

981(a)(1)(A). 

WHEREFORE, Plaintiff, the United States of America, requests:

1. The Defendant Asset be proceeded against according to the law and the rules of 

this Court, and that due notice be given to all the interested parties to appear and show cause why 

forfeiture should not be decreed.

2. The Court, for the reasons set forth herein, adjudge and decree that the Defendant 

Asset be forfeited to the United States of America and disposed of in accordance with existing 

laws, together with costs, and for such other relief as this Court deems proper and just.

Respectfully submitted,

DATED: June 12, 2020 DEBORAH CONNOR, CHIEF

MONEY LAUNDERING & ASSET RECOVERY 

SECTION

Woo S. Lee, Deputy Chief

Shai D. Bronshtein, Trial Attorney

Teresa C. Turner-Jones, Senior Trial Attorney

Criminal Division

United States Department of Justice 

1400 New York Avenue NW

Washington, DC 20005

Telephone: (202) 616-5950

Shai.Bronstein@usdoj.gov

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ARIANA FAJARDO ORSHAN

UNITED STATES ATTORNEY

BY: /s/ Adrienne E. Rosen

Adrienne E. Rosen

Assistant United States Attorney

Court ID No. A5502297

U.S. Attorney’s Office 

99 NE 4th Street, 7th Floor

Miami, Florida 33132

Telephone: (305) 961-9338

Facsimile: (305) 536-4089

Adrienne.Rosen@usdoj.gov

Attorneys for Plaintiff

UNITED STATES OF AMERICA

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