Prosecutors said Imelda Cuellar operated {blank} that received bribe payments disguised as consulting fees but performed "little to no legitimate work."

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Imelda Cuellar operated shell companies—businesses with no significant assets, employees, or operations beyond a mailing address—that received over $600,000 in bribe payments from Azerbaijan and Mexico. Federal prosecutors alleged these were sham consulting contracts for work Imelda never actually performed. Shell companies are a common money laundering tool because they obscure beneficial ownership. The Anti-Money Laundering Act of 2020 now requires beneficial owners to be reported to FinCEN (Financial Crimes Enforcement Network) to combat this tactic.

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