DOJ’s Fraud Division Secure Revocations Against Cartel & Trafficking-linked Business Entities

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The Delaware Department of Justice has secured revocations of corporate charters or certificates of formation on multiple Delaware-registered business entities that are connected to criminal entities. This includes a Venezuelan cartel and a federally sanctioned online pharmacy based in Argentina. After a November hearing, the Delaware Court of Chancery canceled the corporate charter of Water Hill Corp, SMILEPAYMENTS LLC and SMILE TECHNOLOGIES S. A LLC. There are two remaining entities that are awaiting revocation pending liquidation and dispersal of their assets. The operators of these entities have been federally indicted – the businesses used to launder money and the illicit trafficking of commonly abused drugs into the U.S.

Additional information from the AG’s Press Release:

Following a November 22 hearing, the Delaware Court of Chancery canceled the corporate charter of Water Hill Corp., SMILEPAYMENTS LLC, and SMILE TECHNOLOGIES S.A. LLC. Two remaining entities — Oyster Investments LLC and 200G PSA Holdings LLC— are awaiting revocation pending liquidation and dispersal of their assets.

The three canceled entities and Oyster Investments LLC are linked with an online pharmacy, Goldpharma, which has been sanctioned by the U.S. Department of the Treasury’s Office of Foreign Asset Control (OFAC) and whose operators have been federally indicted. The business entities in question were used to launder money associated with Goldpharma’s illicit trafficking of commonly abused pharmaceuticals — including Tramadol, Alprazolam, Carisoprodol, Diazepam, Codeine, and Tapentadol — into the United States.

The fifth entity, 200G PSA Holdings, LLC, is associated with the Cartel of the Suns, an organization believed to be comprised of upper-echelon members of the Venezuelan armed forces which trafficked cocaine into Mexico and the United States on behalf of the Revolutionary Armed Forces of Colombia (FARC).

Assets held by the two pending entities include, in the case of Oyster Investments LLC, several beachfront properties in Florida with an estimated value of $1 million to $1.5 million; and, in the case of 200G PSA Holdings LLC, a private airplane.

This matter was led for the DOJ by Deputy Attorney General Oliver Cleary, with support from Paralegal Courtney Patas and oversight by Director of Impact Litigation Christian Douglas Wright. It follows an investigation led by OFAC. OFAC and the Delaware DOJ share a longstanding partnership in the fight against criminal business entities, and entered a memorandum of understanding (MOU) to further facilitate their collaboration in September 2020.


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