On May 3, police in Miami scooped up three people who were decidedly not common criminals—Thomas Clarke and Jose Alejandro Hurtado, brokers for Wall Street firm Direct Access Partners, and Maria de los Angeles Gonzales, a vice president of Venezuela's state-controlled bank Banco de Desarrollo Económico y Social de Venezuela (Bandes).

Clarke and Hurtado are accused of paying about $5 million in kickbacks to Gonzales to influence her to steer Bandes' securities investment business to Direct Access Partners. A federal indictment filed May 7 charges the trio of executives with money laundering, conspiracy and violations of the Foreign Corrupt Practices Act (FCPA) and the Travel Act.

First enacted in 1961, the Travel Act has been a little-used, but powerful, tool in federal prosecutors' arsenal. The statute has a broader reach than the FCPA, allowing federal prosecutors to not only charge foreign nationals who receive bribes from U.S.-based companies, but also to reach a variety of criminal activity that may not on its face violate federal law.