Browne’s Dealings with the Odebrecht Conglomerate

  1. Sources also informed Applicant’s Investigators that Browne accepted a €3 million bribe in return for hiding banking records related to illegal payments from the Brazilian construction company. This source reporting was confirmed through press reporting and court documents, including a law enforcement cooperator who shared information with Brazilian prosecutors and a former Odebrecht lawyer, Rodrigo Tacla Duran
  2. Specifically, Meinl Bank Antigua (“Meinl Bank”) was used to launder money paid out as bribes in the context of the Odebrecht scheme.1
  3. Meinl Bank was based in Antigua and was originally a part of the Meinl Bank Group from Austria. At the time, it operated as a separate entity, focusing primarily on offshore banking services.
  4. Meinl Bank was used as a central hub for laundering bribes and facilitating illicit financial activities across multiple countries. The bank only had three employees, and operated as

I am also aware that certain of these allegations were corroborated in reporting in the Spanish-language news source, El Pais.

a front for irregular payments, with its headquarters based in São Paulo within the Antiguan consulate.

  1. A former Odebrecht lawyer, who also cooperated in the Brazilian criminal investigations, confirmed that the €3 million was paid by Odebrecht to Browne, and that the payments were made to ensure that Antiguan authorities would not cooperate with other foreign authorities investigating Odebrecht’s activities. According to the same source, Caseroy James, the Antiguan Ambassador to the UAE, and Luiz Franca, the Antiguan honorary consul in São Paulo, facilitated these payments by coordinating between Odebrecht executives and Antiguan officials. Investigation into The West Indies Oil Company:
  2. Fancy Bridge Limited (“Fancy Bridge”) is a publicly identified major owner of WIOC. According to public sources, Fancy Bridge played a central role in the acquisition of WIOC under Browne’s administration. Specifically, the negotiations for the WIOC acquisition were conducted through Xiao Jianhua (“Xiao”), a Chinese Canadian billionaire.
  3. According to public sources, in 2017, Xiao was arrested in Hong Kong and taken to mainland China, but at that time held an Antiguan diplomatic passport. This passport was granted only a few days before his capture by Chinese authorities, which Browne issued after appointing Xiao as an ambassador-at-large.
  4. According to sources that have spoken to Applicant’s Investigators, WIOC is functionally owned by Browne and individuals within his inner circle, and the company allows them to obtain profit in the millions per year, while it appears to be state-owned from the outside.
  5. One former WIOC employee told Applicant’s Investigators that Browne holds “a large percentage of shares in the company [WIOC],” which is explicitly separate from the state majority. Another source that Applicant’s Investigators spoke with expressed “absolute certainty”

As to Browne’s ownership of a substantial portion of WIOC, stating that Browne’s control over WIOC was through Fancy Bridge. The source explained that this was common in Antiguan government under Browne, a practice which entitles government ministers to a ‘commission’ of 10% if they introduce a foreign investor. Some of these same sources directed Applicant’s Investigators to media reports about another agreement between the Antiguan government and Fancy Bridge, which allegedly involved the exchange of 175 Antiguan citizenships under the Citizenship by Investment Program (“CIP”) for shares in WIOC (as detailed herein).

  1. Another Antiguan source confirmed to Applicant’s Investigators that Browne has acquired shares since 2015 using this process, from which he would now be receiving dividends. These dividends would amount to millions of dollars per year, according to the company’s financial reports. Moreover, these sources stated to Applicant’s Investigators that Venezuela trades oil with Antigua through WIOC, in contravention of U.S. sanctions on Venezuelan oil exports, although these sources simultaneously underscored the high level of secrecy that WIOC operates under, “even regarding persons with high positions.” These sources also identified members of WIOC staff who were not permitted to join the WIOC workers’ union due to the potential exposure that this could give them to sensitive information.
  2. Despite opposition politicians raising questions as to the ownership of shares in WIOC, the Antiguan government is nonetheless still referenced by WIOC’s 2022 annual report as its largest shareholder, with 46% of shares after some have been divested to the public in 2021. According to public reports, this divestment was for 10% of the company’s shares and was valued at $19 million.
  3. According to a source from Venezuela, Browne is engaged in fraud via WIOC in order to embezzle money from the sale of oil with the help of Petróleos de Venezuela, S.A.

(“PDVSA”). This source explained that the scheme was enacted after Browne’s appointment as Antigua’s Minister of Finance in 2014. The same source from Venezuela stated that WIOC is likely not primarily state-owned and works as an orchestrated scam, stating: “PDVSA supplies oil to WIOC for free, and WIOC sells it. When PDVSA seeks payment from the government of Antigua, the latter denies ownership of WIOC, stating that WIOC is not its responsibility. Consequently, PDVSA remains unpaid for the oil, while the company’s stakeholders consistently profit from the arrangement.”

  1. Another former WIOC employee confirmed these reports to Applicant’s Investigators, stating: “Regarding the concerns over the lack of transparency – it is very real, and it likely won’t get much better as the company is committed to maintaining that secrecy”. The source explained, “Browne’s financial actions within the company are not usually praised by the WIOC employees”.
  2. According to public information, in 2021, the company Half Moon Bay Holdings threatened to file an injunction against Antigua’s government for selling shares of WIOC to the public because Antiguan government owed Half Moon Bay Holdings $18 million as part of a $50 million compensation for expropriating the Half Moon Bay Resort in 2007. A court ruling ultimately prevented the government from selling shares in WIOC until the debt was fully repaid, as these shares are considered a potential source of repayment. Applicant’s Investigators understand that Antigua’s government still owes $10 million to the company, although some portion of this debt may have been repaid from proceeds of the Alfa Nero sale.

** THIS IS A EXCEPT FROM AN AFFIDAVIT FILED IN US FEDERAL COURT ***