In May 2013, the DOJ unsealed criminal FCPA, Travel Act, anti-money laundering and conspiracy charges against two employees of the New York broker-dealer Direct Access Partners LLC (DAP), as well as Travel Act, money laundering and conspiracy charges against Maria de Los Angeles Gonzalez de Hernandez, vice president for finance of the Economic and Social Development Bank of Venezuela. At the same time, the SEC brought civil charges of securities fraud, aiding and abetting, and failure to keep proper records in violation of the Securities Laws against the same two defendants, the wife of one of the defendants, and a relative of the other. The DAP case involved a labyrinthine kickback scheme involving the payment of millions to Gonzalez through Swiss and Panamanian entities. Those payments, and the defendants’ profits, were created by marked-up transaction fees on economically riskless bond trading undertaken by DAP on BANDES’ behalf.