A U.S. Department of Justice investigation documented how Sargeant Marine paid bribes to PDVSA officials to obtain confidential information and favor contracts for the purchase of Venezuelan asphalt. The file reveals intermediaries, shell companies, bank accounts in the U.S. and Panama, payments calculated per barrel, and even coded language: some officials were identified as “Oiltrader,” “Tony,” and “Tony 2,” while the insider information was referred to as “Chocolates.”
The Sargeant Marine case represents one of the most revealing judicial files from the U.S. to understand how certain corruption networks operated around Petróleos de Venezuela, S.A. (PDVSA). These are not mere political allegations or accusations derived solely from journalistic testimonies. A substantial portion of the facts is documented in the files of the U.S. Department of Justice and, most importantly, in admissions made by the company itself and several participants who pleaded guilty in federal courts.
On September 22, 2020, Sargeant Marine Inc., a former asphalt company based in Boca Raton, Florida, pleaded guilty to conspiracy to violate the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA), agreeing to pay a criminal fine of $16.6 million. The Department of Justice established that the investigated conduct spanned three countries—Brazil, Venezuela, and Ecuador—and extended over approximately eight years.
The Venezuelan dimension is particularly significant because the commercial objective differed from those in the other countries involved. According to the DOJ, Sargeant Marine paid bribes to obtain contracts related to state-owned oil companies. In Venezuela specifically, it sought to purchase asphalt from PDVSA, utilizing insider information and the involvement of officials from the state oil company itself.
Four PDVSA Officials and a Commodity Called “Chocolates”
According to admissions from Sargeant Marine collected by the Department of Justice, between approximately 2012 and 2018, the company bribed four PDVSA officials. In exchange, these officials provided insider information and assisted in steering asphalt purchase contracts from the Venezuelan oil company to a nominee from Sargeant Marine.
The file also shows how aware the participants were of the need to hide their communications. Some PDVSA officials receiving bribes were identified in emails and messages by codenames: “Oiltrader,” “Tony,” and “Tony 2.” The insider information provided from within PDVSA was dubbed “Chocolates.”
This was not merely a system of illegal payments. The value of the operation also depended on access to information that competitors did not have. This component turns the case into a snapshot of a fundamental risk within a state enterprise: the potential for officials with access to confidential business data to transform that information into a commodity to be sold to private parties interested in gaining a contractual advantage.
The Intermediary Who Turned Commissions into Bribes
The structure designed to conceal the payments had several layers. Sargeant Marine admitted that it used fake consulting contracts with an intermediary. The so-called commissions were transferred to bank accounts in the U.S. and offshore that were controlled by that intermediary, who later used part of the money to pay PDVSA officials on behalf of the company.
A subsequent DOJ file against Daniel Comoretto Gomez allows for a more precise observation of how that machinery functioned.
According to the criminal information filed in the Eastern District of New York, between 2011 and October 2015, Comoretto Gomez, Hector Nuñez Troyano, David Díaz, and others participated in a scheme whereby Venezuelan officials received bribes to assist first another asphalt company and later Sargeant Marine in obtaining contracts to buy asphalt from PDVSA.
The court document notes that in 2011, several participants traveled to Puerto Rico to meet with executives of an asphalt company. There, they agreed on a payment mechanism aimed at securing contracts for the purchase of asphalt from PDVSA. By 2012, according to the DOJ, a similar arrangement was established with Sargeant Marine.
And here appears one of the most revealing facts in the entire file: the commission was directly linked to the volume of oil business.
According to the court document, between 2011 and 2015, the companies involved paid the intermediary David Diaz a commission of approximately 45 cents for each barrel of asphalt purchased from PDVSA. Diaz later used part of those commissions to pay bribes to officials and other participants. In other words, the economic incentive for the intermediary increased with the volume of asphalt purchased.
$518,000 Transferred Between the U.S. and Panama
The court documents allow for tracking part of the money’s journey. According to the Department of Justice, between approximately September 2013 and January 2015, David Diaz transferred around $518,000 to Comoretto Gomez and Hector Nuñez Troyano on behalf of the involved companies, including Sargeant Marine. The funds left accounts controlled by Diaz in the United States and Panama and arrived at Panamanian accounts owned by a shell company controlled by Troyano.
Troyano, in turn, transferred part of those funds to a U.S. account controlled by Comoretto Gomez.
The file also identifies approximately $229,000 in bribes sent to Comoretto Gomez between April 2012 and September 2014. Most of these payments used accounts located outside the United States, particularly in Panama, before ending in a Bank of America account in the U.S. Around 22 transfers passed through bank accounts located in New York, a circumstance that helped connect the scheme financially with U.S. jurisdiction.
The structure shows a recognizable pattern: a seemingly legitimate contract or commission, intermediary, bank account, shell company, international transfer, and finally, the beneficiary linked to the state enterprise.
Hector Nuñez Troyano: From PDVSA to the Federal File
One of the central figures in the Venezuelan chapter was Hector Nuñez Troyano, officially identified by the Department of Justice as a former Venezuelan official and former PDVSA employee.
Nuñez Troyano pleaded guilty in March 2019 to conspiracy to commit money laundering. The case was filed in the Eastern District of New York under the file 19-CR-135-ENV.
His case is directly related by the DOJ to the cases against Sargeant Marine, Daniel Sargeant, David Diaz, Jose Tomas Meneses, Daniel Comoretto Gomez, and other participants in the investigation.
This is important because the corporate case was not isolated. The Department of Justice built a network of criminal procedures around individuals who occupied different roles within the operation: executives, traders, intermediaries, and Venezuelan officials.
A Sargeant Marine Executive Also Pleaded Guilty
Criminal responsibility didn’t just end with the intermediaries. The Department of Justice confirmed that Daniel Sargeant, then a senior executive at Sargeant Marine, pleaded guilty in December 2019 to conspiracy to violate the FCPA and conspiracy to commit money laundering. His case was filed as United States v. Daniel Sargeant, 19-CR-319-ENV.
Jose Tomas Meneses, a trader at Sargeant Marine; David Diaz, the intermediary from the Venezuelan scheme; and Hector Nuñez Troyano also pleaded guilty. The DOJ also documented the prosecution of other individuals linked to the company’s international schemes.
The Department of Justice’s 2020 annual report indicated that ten individuals had pleaded guilty for their roles in the Sargeant Marine schemes, including a senior executive, two traders, six agents, and a former Venezuelan official who had received bribes. A second former Venezuelan official had been charged with conspiracy to commit money laundering.
The Method Was Not Exclusively Venezuelan
Sargeant Marine admitted that the mechanism used in Venezuela was part of an international pattern. In Brazil, the company acknowledged bribing government officials and Petrobras executives. To conceal them, it used fake consulting contracts, fake invoices, and international transfers to companies controlled by intermediaries.
In Ecuador, Sargeant Marine admitted to bribing an official from the state oil company Petroecuador to secure an asphalt supply contract in 2014. Here, the same architecture reappeared: an intermediary close to the decision-maker, a supposed consulting contract, and commissions that were later used to finance the bribe.
The common element was, therefore, the use of seemingly legitimate business mechanisms to generate and move the money destined for public officials.
Sargeant Marine, Vitol, and a Necessary Precision
The subsequent corporate history requires precision. In December 2015, Vitol announced that it would acquire 50% of Sargeant Marine’s asphalt business. The operation gave rise to VALT, the joint venture that began operations in 2016. Official documentation from the Irish competition authority confirms that Vitol and Sargeant Marine would jointly control Asphalt Logistics & Trading, each with a 50% share.
Therefore, describing that initial transaction simply as a majority acquisition of Sargeant Marine by Vitol would be inaccurate. In March 2019, Vitol announced a second transaction: it agreed to purchase the remaining 50% of VALT, which meant that the asphalt business would become 100% owned by Vitol and integrated into its core operations.
The timeline is especially relevant because the conduct admitted by Sargeant Marine spanned approximately from 2010 to 2018, while the partnership with Vitol began during that period. That, however, does not mean that the criminal responsibilities admitted by Sargeant Marine can be automatically attributed to Vitol. The DOJ’s criminal agreement specifically identifies Sargeant Marine and the individuals prosecuted for their respective conducts. Any additional attribution must be supported separately by judicial evidence.
Venezuela: Corruption from Within PDVSA
The Sargeant Marine case allows for an observation of something that often disappears behind the large figures of Venezuelan corruption. To manipulate an oil contract, it was not always necessary to control the entire PDVSA.
It was enough to have officials in strategic positions capable of providing confidential information, intervening in commercial processes, or facilitating contracts. The money could then flow through intermediaries, false consultancies, shell companies, and bank accounts outside Venezuela.
This is precisely what makes the term “Chocolates” relevant. Insider information from PDVSA had economic value because it allowed reducing uncertainty and provided an advantage over other market participants. When a public official provides that information in exchange for money, corruption ceases to simply be the illegal payment of a commission: it directly affects competition and the integrity of the contractual process.
The Real Risk for a New PDVSA
The file gains renewed importance for any process aiming to recover the Venezuelan oil industry.
Rebuilding PDVSA means not only recovering wells, refineries, pipelines, terminals, and production capacity. It also requires rebuilding the controls that determine who can contract, who accesses confidential information, who modifies specifications, who evaluates offers, who authorizes payments, and who can establish relationships with intermediaries. Sargeant Marine demonstrates why.
The company admitted to bribing four PDVSA officials to obtain internal information and contractual assistance. It utilized an intermediary, fictitious consulting agreements, and U.S. and offshore accounts to conceal payments. In one documented part of the scheme, commissions were even calculated based on each barrel of asphalt purchased. Corruption could thus be incorporated into the very cost of the operation.
A Documented Warning for the Venezuelan Oil Reconstruction
The Sargeant Marine case should not be read solely as the story of a scandal that occurred over a decade ago. It also serves as a forensic manual on the vulnerabilities that any serious reform of PDVSA must address.
Anti-corruption controls will need to look beyond the formal owners of contracting companies. It will be necessary to identify ultimate beneficiaries, intermediaries, and consultants; review payments and commissions; detect shell companies; control conflicts of interest; protect confidential business information; audit contractual modifications; and establish mechanisms capable of detecting relationships between officials and suppliers.
Because the lesson left by the U.S. file is uncomfortably simple: to compromise the integrity of a gigantic oil company, it was not necessarily required to control its entire structure.
It was enough to have a few officials with access, an intermediary willing to move the money, a company interested in gaining an advantage, and a bank account to close the circuit.
In the case of Sargeant Marine, U.S. justice reconstructed that circuit. And in Venezuela, a part began within PDVSA.