Corrupt networks worldwide often transact in U.S. dollars, currency that, under U.S. law, remains American property wherever it travels. This extraterritorial reach stems from the Foreign Corrupt Practices Act (FCPA), which applies to “any person” with sufficient ties to the United States and to dollar‑denominated transactions routed through U.S. financial systems.
The FCPA creates a powerful legal mechanism for fighting corruption beyond American borders. Financial executive Shiva Ramnarine has identified this jurisdictional principle as a potential game-changer for addressing entrenched corruption in regions where domestic enforcement consistently fails. Drawing on over three decades of experience in financial leadership roles, he transforms the global dominance of the U.S. dollar into a strategic anti-corruption tool that circumvents compromised local institutions.
While serving as Chief Financial Officer at Telecommunications Services of Trinidad and Tobago (TSTT), Ramnarine implemented governance and oversight systems that saved the company approximately $160 million in annual non labour related costs by identifying and eliminating what he terms “inert hidden corruption”, wasteful expenditures and vendor-influenced procurement decisions that drain resources while avoiding conventional anti-corruption scrutiny.
Trinidad and Tobago’s Opposition Political Party Allegations
Opposition figures have repeatedly alleged that approximately US $4 million was paid to NCB Global Finance, an entity linked to a government minister’s brother, as part of a debt‑purchase scheme that critics contend represents self‑dealing at the public’s expense. While the government has dismissed these claims as politically motivated, the Opposition has repeatedly attempted to tie the Minister’s unprecedented recusals from Cabinet 137 times to payments to NCB Global.
“Four billion dollars,” Shiva Ramnarine states, if correct, is very questionable. “If that is the amount of money that flowed through an alleged single corrupt scheme in Trinidad, then every American dollar in that transaction falls under U.S. jurisdiction.”
Transparency advocates say such schemes exemplify what Ramnarine identifies as sophisticated corruption: transactions structured to appear legitimate while channeling public resources to politically connected entities. These arrangements typically involve complex financial mechanisms that create plausible deniability for participants while enriching insiders.
According to transparency advocates, such schemes represent a particularly damaging form of corruption because they systematically divert resources from critical public services while eroding institutional accountability.
The “Dollar Trap”
When politically connected actors intervene to shut down investigations, evidence disappears, and local courts prove unwilling to prosecute the politically connected, Shiva Ramnarine sees an alternative path forward through U.S. jurisdiction over dollar transactions.
“The U.S. dollar is their property, and if it can be shown that it’s being used for a corrupt purpose, then absolutely we will work along with them,” Ramnarine explains. This approach potentially exposes corrupt officials to U.S. financial crime laws, regardless of their political protection at home.
Investigations into high-level corruption in Trinidad and Tobago frequently falter because senior officials impede probes or reassign investigators, while the judiciary issues inconsistent rulings and avoids challenging secret discretionary accounts. Anti-corruption bodies lack sufficient funding and technical expertise, and records routinely vanish when politically connected suspects intervene. These factors create an environment where protected actors evade accountability.
The U.S. Department of Justice has successfully prosecuted foreign officials under money laundering and FCPA statutes when transactions involved U.S. dollars or passed through U.S. correspondent banks. For example, in United States v. Alvaro Ledo Nass, a former PDVSA official pleaded guilty in March 2023 to conspiracy to commit money laundering and FCPA violations after receiving bribes tied to Venezuelan currency exchange schemes. Similarly, in May 2024, Fernando Vuteff admitted to laundering over $4 million as part of a $1.2 billion bribery scheme involving PDVSA before funneling proceeds into U.S. real estate.
Concerns Over the Trinidad and Tobago and Venezuela “Dragon Gas” Agreement
Shiva Ramnarine has referenced the Opposition Political Party of Trinidad and Tobago who raised concerns over the transparency of the Dragon Gas agreement with Venezuela, pointing to PDVSA’s documented history of corruption. By tracing U.S.-licensed dollar flows into the project, authorities could ensure payments aren’t diverted for illicit purposes. His concerns are compounded by the role of Stuart Young, who served as Minister of Energy and, according to the opposition, made numerous unpublicized visits to Venezuela. It was only through the Freedom of Information Act was the opposition able to obtain information on these trips in March 2025.
The controversy deepened when Delcy Rodríguez, Vice President of Venezuela and a sanctioned individual on a U.S. blacklist, was received by the Trinidad government during pandemic restrictions while ordinary citizens were barred from entering the country. This raised further questions about the nature and transparency of the negotiations.
The agreement represents a high-risk case due to Venezuela’s extensive history of corruption in its energy sector. Critics note that partnerships with PDVSA have frequently served as vehicles for embezzlement. International oversight mechanisms focused on dollar-denominated transactions could provide crucial transparency in an arrangement otherwise shielded from effective scrutiny.
Shiva Ramnarine’s Strategic Framework
Shiva Ramnarine outlines a four-part approach to utilizing U.S. currency laws to combat corruption:
- First, meticulously document dollar-denominated flows, including those through offshore correspondent accounts.
- Second, coordinate with U.S. authorities, particularly the DOJ’s Criminal Fraud Section and the FBI’s International Corruption Unit.
- Third, utilize Title 18 money‑laundering statutes to prosecute the laundering of corrupt proceeds, regardless of where the underlying bribery occurred.
- Finally, develop public-private partnerships with financial institutions to flag suspicious dollar flows and with civil society watchdogs to maintain pressure for transparency.
Through Mobius Consulting Panama, founded in 2022, Ramnarine has developed digital solutions specifically designed to identify patterns of financial misconduct that traditional auditing often misses. These systems combine forensic accounting with advanced data analytics to detect anomalies that might indicate corruption. By integrating artificial intelligence into oversight processes, these tools establish an objective framework for identifying suspicious activities, eliminating the need for potentially compromised human reviewers.
Implementation Challenges and Practical Applications
Despite its potential effectiveness, implementing the “dollar trap” strategy faces obstacles. Political resistance from powerful actors presents the most immediate challenge. Additionally, successful implementation requires complex international coordination between justice agencies, financial intelligence units, and regulatory bodies, a diplomatic and logistical challenge even under ideal circumstances.
Technical barriers also exist, as corruption networks increasingly utilize cryptocurrency, shell companies, and mechanisms designed to obscure beneficial ownership. Developing nations often lack the specialized forensic accounting capabilities needed to untangle these complex financial structures.
Nevertheless, high-profile cases demonstrate the viability of this strategy. The investigation into Malaysia’s 1MDB scandal shows how U.S. financial jurisdiction can be applied to foreign corruption. Despite political protection within Malaysia, individuals connected to the fraud faced prosecution under U.S. law because portions of the scheme involved dollar-denominated transactions. Similarly, Brazil’s Operation Car Wash exposed how dollar transactions created legal vulnerability for corrupt officials at Petrobras.
By treating dollar‑denominated transactions as potential evidence admissible in U.S. courts, this currency‑focused strategy offers a pragmatic way to hold corrupt actors accountable when local systems fail. Shiva Ramnarine continues to refine these methods through Mobius Consulting, helping governments and businesses harness U.S. legal tools to dismantle entrenched corruption networks.