Tel. +58-212-237.6877 , +58-212-237.8277, +58-212-237.7526. Fax +1-786-228.0559. Mob. +58-414-118.9381
E-Mail : luis@aguilar.pro or laa@laaguilar.com or laaguilar@aguilarfirm.com (PGP Services Enabled). Boca Raton, Florida, September 10, 2012.
Mmes. and Messrs.
Financial Industry Regulatory Authority FINRA Investor Complaint Center 9509 Key West Avenue
Rockville, MD 20850-3329. United States of America. Ph. (301) 590-6500.
In memoriam of Josef Grootkerk Zeldenrust, Luis Enrique Dávila Perez, Luisa Elena Aguilar Pardo, Janusz Korczak and those others who valiantly have made a difference for the lives of others. This is a matter where there is no space for grays. One or several individuals are lying and one or several are being truthful.
Via: Federal Express US Air bill 8007 6256 1542. Re.: Complaint Filing ID 1960837.
Dear Mesdames and Messieurs,
My name is Luis Alejandro Aguilar Pardo, 56 years old, with address at 3801 Bridgewood Drive, Boca Raton, Florida 33434. Ph. 561-251.7697. Email luis@aguilar.pro.
Please use my email address luis@aguilar.pro as primary means of communications. I authorize the use of electronic messages and electronic transmission of notices, requests and decisions, Other alternative email addresses are shown in the letterhead.
I represent Pimjo Trust CV, a limited partnership; most regretably a client of Oppenheimer & Co., Inc., a New York based brokerage firm.
Note be taken that all persons mentioned in this document acting for Oppenheimer & Co., Inc. are 1
actual employees of Oppenheimer & Co., Inc. and they are not independent persons or third parties. I am not allowed to practice law in the United States of America.
Pimjo Trust CV has no legal counsel since all its funds are being withheld by Oppenheimer & Co., Inc. and has no means to pursue its defense.
From information and belief, knowingly, Oppenheimer & Co., Inc. has engaged in the predatory practices of unexcusably restricting and delaying access to the funds, assets and information of Pimjo Truct CV accounts in order to conceal its purported illegal actitivies from Pimjo Trust CV, the federal regulatory agencies of the United States of America, self-regulatory agency of the United States of America, the national regulatory agencies of Venezuela in banking, securities and foreign exchange control, created an illegal flow of money unsupervised by the financial intelligence agencies empowered to monitor the legality of transfers of money.
I filed complaint Filing ID 1960837 on August 7, 2012.
I complained about Oppenheimer & Co., Inc. Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) and New York Executive Vice-President and General Counsel Dennis1 P. McNamara (CRD # 2938486).
I now include in my complaint Messrs. Albert Grinsfelder Lowenthal, President and CEO (CRD # 313519),Allen B. Holeman, Managing Director and Chief Compliance Officer of Oppenheimer & Co., Inc. (CRD # (1060910), and Arthur W. Lewis, Oppenheimer & Co., Inc. Boca Raton, Florida, Office Branch Manager and Broker (CRD # (1438899) and the firm Oppenheimer & Co., Inc. (CRD # 249) itself.
I represent Carisma Prima Limited (IRS assigned FEIN 98-0632390), a New Zealand trustee company, who acts as the trustee of the Joseph Trust (IRS assigned FEIN 98-6065855), a trust settled in accordance with New Zealand law on July 7, 2009, who in turn is the Managing / General Partner of the limited partnership Pimjo Trust, CV (IRS assigned FEIN 98-1035735), an originally Dutch limited partnership created on July 19, 2001 whose Deed of Creation was amended and reinstated on July 9, 2009.
The address of Carisma Prima Limited, the Joseph Trust and Pimjo Trust CV is c/o Aguilar & Aguilar Limited, Level 31, Vero Centre, 48 Shortland Street, Auckland 1140, New Zealand. Tel. +64-9-363.3391. Fax +64-9-358.7340. Fax +1-786-228.0559.
Pimjo Trust CV is the account holder of account number A14-0505833-452 at Oppenheimer & Co., Inc. 85 Broad Street, New York, NY 10004, USA, (sometimes also referred to as the “Oppenheimer & Co., Inc.).
Pimjo Trust CV appears as the account holder or account title of a certain undisclosed and secret checking account at UMB Bank NA, account number 26201338505041, connected with Oppenheimer & Co., Inc.
Please find below an image of check 1004 which evidences the existence of the account.
THE STRUCURE
Contrary to Oppenheimer & Co., Inc. allegations about the complexity of the corporate structure created and managed by its own employees, the structure is fairly simple.
Carisma Prima Limited, a New Zealand private trustee has one shareholder named Aguilar & Aguilar Limited who holds in trust those shares - today - for the benefit of such entity to be designated as a result of the successful conclusion of the Plan of Revitalization dated January 17, 2012.
Carisma Prima Limited is the trustee of two trusts namely, the Xavier Trust and the Joseph Trust. The Xavier Trust is the Limited Partner of a very simple limited partnership named Pimjo Trust CV while the Joseph Trust is the Managing / General Partner of Pimjo Trust CV.
The limited partnership of Pimjo Trust CV is governed by the Deed of Creation as Amended and Reinstated as of July 9, 2009.
The representation of Pimjo Trust CV may be accomplished by the acts of the Director / Managing Director of Carisma Prima LImited as trustee of the Joseph Trust acting as the Managing / General Partner of Pimjo Trust CV or by a duly issued Power of Attorney.
THE COMPLAINT
The complaint filed with your office contains the following 29 statements: “I handle the hypothesis that Carisma Prima Limited as Trustee of the Joseph Trust acting as Managing Partner of the limited partnership Pimjo Trust CV might be involuntarily involved in a case dealing with (1) illegal money movements, (2) violations of foreign exchange controls, (3) lack of regulatory compliance and supervision, (4) actions contemplated as crimes of organized groups qualified as organized associations under Ley Organica contra la Delincuencia Organizada)in Venezuela, (5) failures of mandatory Anti-money laundering compliance programs and the effects of reincidence after Oppenheimer & Co., Inc. NYSE Hearing Board Panel Decision 05-181 of December 29, 2005,(6) failures of mandatory Anti-money laundering compliance programs and the effects of reincidence after John Gayle Pettus NYSE Hearing Board Decision 06-82 of June 27, 2006, (7) transactions performed without trading authorization, (8) money movements out
of the account without authorization or registered signatory, (9) opening and operating an account 26201338505041 at UMB Bank N.A. without authorization and authorized signatory,(10)concealing from Compliance officers vital data of the client, (11) violation of conflict of interests rules and Code of Ethics, (12) intentional lack of KYC and compliance reviews, (13)illegal exercise of businesses in the financial sector in Venezuela without authorization, (14) performing illegal banking activities such as wire transfers expressly reserved to authorized banks, (15) concealing information concerning compliance duties, (16) redirecting clients´s mail to brokers controlled´addresses different from client´s address, (17) acting as director of client without having cleared conflict of interests and providing misleading and false information about it, (18) denial to supply information concerning transactions done with account 26201338505041 at UMB Bank NA, (19) supplying false information about the Final Beneficiary Owner in W- 8BEN form, (20) filing misleading information to SEC in Form 10-K concerning the nature of their business and their locally operated entity in Venezuela, (21) performing actions against Ley Contra Ilícitos Cambiarios in Venezuela, (22) filing misleading information to SEC about operations in Venezuela and sources of revenues, (23) recognizing and taking possession of revenue produced by illegal activities in Venezuela, (24) exerting undue and unjust pressure threatening client´s representative with an interpleader action while blocking access to the account in order to, finally, cover up weaknesses due to intentional violation of laws of Venezuela, (26) performing a movement of funds circa
February 15, 2012 while the account was allegedly restricted by Oppenheimer and there was no authorized signatory (26) avoidance of income taxes in Venezuela in order to cover up other hypothesis mentioned before, (27) avoidance of value added taxes in Venezuela in order to cover up hypothesis mentioned before, (28) failure to recognize authority of client claiming lack of understanding of a "complex multi-national corporate structure" created without authorization by Oppenheimer employees and with the participation of those employees as directors of the "complex multi-national corporate structure" until their forced resignation in November 2011, (29) possibly filing misleading information in forms U4. (30) I handle the hypothesis that the findings mentioned in the NYSE decisions previously mentioned about transactions through wire transfers and intra-Firm journal transfers between
unrelated clients "for no apparent economic benefit" might have involved the use of the account 26201338505041 at UMB Bank N.A., the client´s account in Oppenheimer & Co., Inc. and that the economic benefit might have been illegal foreign exchange transactions where the other part of the complete transaction was done in Bolivars exchanged in Venezuela. I reserve the right to add more circumstances.”
This complaint does not address the possibilities of violations of the Foreign Corrupt Practices Act of the United States of America. However, for information and beief, it is likely that, in order to maintain the scheme created and operated by Oppenheimer, Co., Inc., the probability of transgressions to Foreign Corrupt Practices Act of the United States of America is larger than zero.
I must start by saying that, since Pimjo Trust CV and its undesigned representative have been victims of the concealment and avoidance tactics used by Oppenheimer & Co., Inc., and its agents and since we lack inquisitive powers to find out the truth behind Oppenheimer & Co., Inc.´s behaviors, we only manage educated hypothesis about what the real status quo should be.
Pimjo Trust CV has found itself involuntarily immersed within this stage of wrongdoings. 1.- Illegal movements of money.
The first allegation presented to your consideration is that , from information and belief, Oppenheimer & Co., Inc., through its secret, illegal, fictive, unregistered and unauthorized branch office located in the city of Caracas, Venezuela, under the cover of a local company named today “Brisbane, Mendes de1 Leon, Pettus y Asociados, representantes de Oppenheimer & Co., Inc.”, was involved in illegal movements of money which affected Pimjo Trust CV.
The movements of money are illegal under three different laws, namely: foreign exchange control laws, banking laws and securities laws.
Venezuela has enacted and enforced a foreign exchange control system since February 5, 2003. During the period of 9 years since its inception, the foreign exchange control system has changed in many ways. One element, though, remained always valid: all transactions with foreign exchange in Venezuela had to be funneled via Banco Central de Venezuela and Comisión de Administración de Divisas (CADIVI) .2 3 Another constant element was that all legitimate transactions with foreign exchange had to be transacted with Operadores Cambiarios , namely authorized banks and authorized foreign exchange agents except,4 perhaps, for certain transactions known as “barters of securities”.
transaction took place. The following acts were enacted and in force for the given dates:
Name of Act Date Enacted Date Abrogated
Ley de Régimen Cambiario May 17, 1995 September 13, 2005 Ley Contra los Ilícitos
Cambiarios.
September 14, 2005 December 27, 2007
Ley Contra los Ilícitos Cambiarios.
December 28, 2007 February 26, 2008
Ley Contra los Ilícitos Cambiarios
February 27, 2008 May 16, 2010
Ley Contra los Ilícitos Cambiarios
May 17, 2010
From the banking laws standpoint, in accordance with Venezuelan law and depending of the date of applicability of the several banking laws enacted since 2001, capturing funds within Venezuela and engaged in transfers of funds or wire transfers are considered either typical or connected banking activities reserved exclusively to banks, savings and loans associations and other financial institutions duly authorized to do business in the banking sector.
Banks, savings and loans associations and other financial institutions do need to be registered and authorized to do business in the financial sector and are subject to the supervision of the administrative authorities overseeing the banking industry, namely: former Superintendencia de Banco y Otras Instituciones Financieras and today Superintendencia de Instituciones del Sector Bancario.
Additionally, wire transfers are subject to reporting requirements with regulatory agencies in order to cooperate with the efforts of financial intelligence agencies around the globe to prevent money-laundering and terrorism financing.
The following acts or statutes were enacted and in force for the given dates:
Name of Act Date Enacted Date Abrogated
Ley General de Banco y Otras Instituciones Financieras
November 13, 2001 July 30, 2008
Ley General de Banco y Otras Instituciones Financieras
Ley General de Banco y Otras Instituciones Financieras
December 23, 2009 August 18, 2010
Ley General de Banco y Otras Instituciones Financieras
August 19, 2010 December 27, 2010
Ley de Instituciones del Sector Bancario
December 28, 2010 March 1, 2011
Ley de Instituciones del Sector Bancario
March 2, 2011
Under the perspective of the securities laws of Venezuela, Brisbane, Mendes De Leon, Pettus y Asociados, representantes de Oppenheimer & Co., Inc. and Oppenheimer & Co., Inc. claim to be “registered financial advisors” in Venezuela and use this fictive character in order to illegally operate in Venezuela. However, Venezuelan securities laws prohibit “registered financial advisors” from selling or receiving securities and money save for strictly their professional fees when acting as “registered financial advisors”.
The following acts were enacted and in force for the given dates:
Name of Act Date Enacted Date Abrogated
Ley de Mercado de Capitales October 22, 1998 August 16, 2010 Ley de Mercado de Valores August 17, 2010 November 4, 2010 Ley de Mercado de Valores November 5, 2010
From information and belief, Oppenheimer & Co., Inc., through its secret, illegal, fictive, unregistered and unauthorized branch office located in the city of Caracas, Venezuela, under the fictive cover of a local company named today Brisbane, Mendes De Leon, Pettus y Asociados, representantes de Oppenheimer & Co., Inc., knowingly and intentionally engaged illegally in the business of transferring funds in Venezuela and in foreign currency in exchange for Bolivars and and engaged in the behavior5 of selling unregistered foreign securities in Venezuela operating in the financial market of Venezuela as an unauthorized brokerage house and engaged in activities reserved to authorized banking institutions. From information and belief, Oppenheimer & Co., Inc., through its secret, illegal, fictive, unregistered and unauthorized branch office located in the city of Caracas, Venezuela, under the cover of a fake local company named today Brisbane, Mendes De Leon, Pettus y Asociados, representantes de Oppenheimer & Co., Inc., - a company that from information and belief is directly or indirectly controlled by
Oppenheimer & Co., Inc., under the supervision of Oppenheimer & Co., Inc. Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) , New York Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) and secret, illegal, fictive, unregistered and unauthorized
I now include in my complaint Messrs. Albert Grinsfelder Lowenthal, President and CEO (CRD # 313519) since he should have actual knowledge of the mischievous behaviors taken place, New York Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) Allen B. Holeman, Managing Director and Chief Compliance Officer of Oppenheimer & Co., Inc. (CRD # (1060910), Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) and the firm Oppenheimer & Co., Inc. (CRD # 249) itself, who, from information and belief, engaged in several million dollars of non-security/investment transactions through wire transfers and intra-Firm journal transfers between a large number of intra-account journals through both unrelated customer accounts as well as employees’ personal and employee-related accounts, without relevant security transactions that - in the findings of NYSE Heraing Board Panel Decision and Hearing Board Decision - appeared to have been mae for no apparent economic benefit.
For information and belief, Mr. Arthur W. Lewis, Oppenheimer & Co., Inc. Boca Raton, Florida, Office Branch Manager and Broker (CRD # (1438899), having had firstly actual knowledge of the illegal conducts, failed to take corrective actions and subnissively followed instructions from New York Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) and Allen B. Holeman, Managing Director and Chief Compliance Officer of Oppenheimer & Co., Inc. (CRD # (1060910) in order to cooperate in concealing the mischievous behaviors.
These practices were discovered, mentioned and sanctioned in Oppenheimer & Co., Inc. NYSE Hearing Board Panel Decision 05-181 dated December 29, 2005 and in John Pettus. NYSE Hearing Board Decision 06-82 dated June 27, 2006. Some practices remained in use irrespective of the conclusions of such decisions.
However, from information and belief, contrary to the findings in Oppenheimer & Co., Inc. NYSE Hearing Board Panel Decision 05-181 dated December 29, 2005 and in John Pettus. NYSE Hearing Board Decision 06-82 dated June 27, 2006, some or all of these practices might have had an economic benefit since they were half the cycle of illegal foreign exchange transactions in which Oppenheimer & Co., Inc.´s clients, under the personal direction and participation of Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) “sold” clients funds in U.S. Dollars in exchange for Bolivars.
Indeed, from information and beief,Oppenheimer & Co., Inc. employees debited the “sold” amount of U.S. Dollars from the account at Oppenheimer & Co., Inc. of the “US Dollar seller-client” and move the U. S. Dollar amount via intra-account journals or wire transfers to “purchaser” of U. S. Dollars (clients, unrelated cients, employees and related employees accounts. Meanwhile, the other end of the transaction an Oppenheimer & Co., Inc.´s broker, employee, employee related person or totally unrelated person -would hand out to, or deposit in a Venezuelan bank account of the “US Dollar seller-client” the Bolivars equivalent of the illegal foreign exchange transaction.
From information and belief, t was necessary for their schema to work to have an account where US dollars credits and debits were transacted and to keep the differential benefits.
From information and belief, at least, Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) opened and used the undisclosed, unauthorized and secret checking account at UMB Bank NA, account number 26201338505041, somehow connected with Oppenheimer & Co., Inc., to further this illegal line of business.
From information and belief, it was illegal for Oppenheimer & Co., Inc. To provide checking account facilities to its clients.
From information and belief, it seems that the true reason that explains Oppenheimer & Co., Inc.´s attitude of concealment and avoidance denying access to the control of the accounts of Pimjo Trust CV -particularly the information about the account at UMB Bank NA - is because of the revelations that would arise after auditing the undisclosed, unauthorized and secret checking account at UMB Bank NA, account number 26201338505041.
From information and belief, these transactions evaded controls and proper reporting requirements regarding movements of funds both in Venezuela and in the United States of America and that the probability of being contaminated with tainted money is larger than zero.
2.- Violations of foreign exchange controls.
As said before, Venezuela has enacted 5 five statutes dealing with foreign exchange control violations during the period 1995 until today.
Name of Act Date Enacted Date Abrogated
Ley Contra los Ilícitos Cambiarios.
September 14, 2005 December 27, 2007
Ley Contra los Ilícitos Cambiarios.
December 28, 2007 February 26, 2008
Ley Contra los Ilícitos Cambiarios
February 27, 2008 May 16, 2010
Ley Contra los Ilícitos Cambiarios
May 17, 2010
From information and belief, from the periods mentioned below, the articles mentioned below of the applicable statutes then in force were violated by Oppenheimer & Co., Inc. and its agents and employees.
Name of Act Articles Violated or Affected Consequences
Ley de Régimen Cambiario of May 17, 1995 until September 13, 2005.
3, 6, 9, 13, 14, 18.
Imprisonment, fines, confiscation and reimbursements. Ley Contra los Ilícitos
Cambiarios of September 14, 2005 until December 27, 2007. 2 (# 3), 3,6, 9,14, Imprisonment, fines, confiscation and reimbursements. Ley Contra los Ilícitos
Cambiarios of December 28, 2007 until February 26, 2008.
2 (#1), 2 (#3), 4, 9, 12, 19, 22 Imprisonment, fines, confiscation and reimbursements. Ley Contra los Ilícitos
Cambiarios of February 27, 2008 until May 16, 2010.
2 (#1), 2 (#3), 4, 9, 12, 19, 22 Imprisonment, fines, confiscation and reimbursements. Ley Contra los Ilícitos
Cambiarios of May 17, 2010 until today.
2 (#1), 2 (#3), 4, 9, 12, 19, 22 Imprisonment, fines, confiscation and reimbursements.
3.- Lack of regulatory compliance and supervision
From information and belief,iIt seems that Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch
Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) neither reported nor updated the records of Pimjo Trust CV with Oppenheimer & Co., Inc.
From information and belief, the aforementioned omissions were adopted knowingly and intentionally. From information and belief, even though Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) served as directors and managers within Pimjo Organization, it looks that no compliance review was performed since well before July 19, 2001.
I have observed that some statements of account of Pimjo Trust CV account number A14-0505833-452 included a page entitled “Account Verification Profile” aimed to update the records of the client. The information supplied by Oppenheimer & Co., Inc. in those statements of account reflect that Pimjo Trust CV is a “widower”, is a “retired” person; that is a natural person - not a partnership - and reachable at the phone number “2122376877" (without country code) which is the phone number of Aguilar & Aguilar, Abogados in Caracas, Venezuela (see letterhead of this letter). The “Investments Objectives” and the “Investment Experience”are both unauthorized and invented.
The text of the “Account Verification Profile” reads as follows:
“Oppenheimer, as a registered Broker Dealer, is required to maintain updated financial information regrading client accounts and to provide clients with certain information on which it is relying. Please take a moment to review the ‘Account Verification Profile’ below that reflects information that you provided about your account. In the event that any of the information is incorrect or incomplete, please submit any changes, in writing, to the Branch Manager named on the profile.”
From information and belief, I presume that these actions were taken deliberately and intentionally -during circa 11 years - since Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) managed to deviate all mail and correspondence to a false address avoiding thus corrective actions by Pimjo Trust CV.
From information and belief, it seems tat, during circa 11 years, the information was deliberatively wrong.
The possibility that the same behavior occurred in connection with UMB Bank NA, account number 26201338505041 is larger tan zero.
From information and belief, I presume that this deliberative concelamnet of information together with the intentional deviation of mail was aimed to avoid detection of incorrect information such as that Pimjo Trust CV was a “retired” “widower” and it may be connected with the method used to extract funds out of the account without having authorization to do so.
From information and belief, Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914), was a participant director of the Pimjo Organization, with full knowledge of the circumstances, perfectly aware of the events which occurred in 2001 by which Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) attempted to take ownership of the assets of Pimjo Organization without authorization and who deviated all correspondence to "Pimjo Trust CV. CCS 82586, P.O.Box 025323, Miami FL 33102, USA".
From information and belief, the address "Pimjo Trust CV. CCS 82586, P.O.Box 025323, Miami FL 33102, USA" is the address of a forwarding and consolidating agent who forwards mail to MBE Venezuela CA, Avenida Orinoco entre Calles Muchuchíes y Perijá, Edificio L&M, Pent House, Las Mercedes, Baruta, Caracas. Tel. +58-212-992.2120, +58-212-992.6781 y +58-212-991.1277.
From information and belief, correspondence arrived via the scheme of using the scheme of the the Miami address of the forwarding and consolidating agent is not made available to Pimjo Trust CV. From information and belief, this is a gross violation of anti-money laundering precautions by Oppenheimer & Co., Inc. who sems to be aware of the existence of the scheme and, presumably , assumes the costs incurred to maintain this scheme in place.
NYSE Hearing Board Panel Decision 05-181of December 29, 2005 found this practice irregular in the following terms:
“In addition, despite apparent anomalies, Oppenheimer did not conduct any regular or periodic reviews of accounts that maintained post office box addresses. A large number of the accounts for apparently unrelated customers maintained the same home and/or business address, many of which were post office boxes or “care of” accounts in Florida. Several groups of apparently unrelated customers also shared addresses in foreign jurisdictions, including an offshore financial center.” (p. 8).
Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) NYSE Hearing Board Decision 06-82 of June 27, 2006 did not contemplate the abnormality of redirecting mail but it is extremely likely that the arrangements were made by Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914).
4.- Actions contemplated as crimes of organized groups qualified as organized associations under Ley Organica contra la Delincuencia Organizada in Venezuela.
Organic Law Against Organized Crime (Ley Orgánica contra la Delincuencia Organizada) was enacted on October 26, 2005.
Article 2 (1) defines organized crime as the actions or omissions of three or more persons with the intention of carrying out the actions described in the statute.
In accordance with article 16 (4), the activities carried out by Oppenheimer & Co., Inc. and its employees may be expressly typified as topologies of organized crimes.
Article 5 states that the sole action of associating with the intention to performed illegal actions constitutes a topology of organized crime.
Article 4 defines the crime of money laundering.
Article 5 covers the hypothesis of money laundering caused by imprudence, negligence, inability or transgressions of the law.
The effects of the statute extends to those who benefit from proceeds obtained from the illegal activities contemplated therein. If such is the case, recognized revenue by Oppenheimer & Co., Inc. contributed from Oppenheimer & Co., Inc., through its secret, illegal, fictive, unregistered and unauthorized branch office located in the city of Caracas, Venezuela, should fall within the topology of the criminal activity. It is my conjecture that “tainted money” may have made its way through the undisclosed and secret checking account at UMB Bank NA, account number 26201338505041, connected with Oppenheimer & Co., Inc.
If “tainted money” is at stake, the participation of the Drug Enforcement Administration should be requested to immediately clear this issue.
5.- Failures of mandatory anti-money laundering compliance programs and the effects of reincidence after Oppenheimer & Co., Inc. NYSE Hearing Board Panel Decision 05-181 of December 29, 2005. Oppenheimer & Co., Inc. was found accountable in NYSE Hearing Board Panel Decision 05-181 of December 29, 2005 of failures to follow mandatory Anti-money laundering compliance programs. From information and belief, in the case of Pimjo Trust CV, the compliance failures were still present until November 2011.
IFrom information and belief, It seems that the records of Pimjo Trust CV were not updated for circa
11 years.
The opening documentation for the account number A14-0505833-452 at Oppenheimer & Co., Inc. show a vicious circle of conflict of interests and mutual circular approvals among the broker-dealers Caracas Office Branch .
The opening documentation was signed by Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) even when the validity and legality of his actions had been challenged and contested.
From information and belief,iIt seems that deliberatively no “Know Your Customer” and “Know Your Customer Clients” reviews were performed during circa 11 years.
From information and belief, it seems that all transfers out of the account were either unsupported by letters from authorized signatories or supported by false letters.
From information and belief, it seems that the information concerning Pimjo Trust CV was deliberately kept wrong. It seems that the documentation concerning Pimjo Trust CV maintained in the files of Oppenheimer & Co., Inc. was that revoked set of documents produced between July 19, 2001 and November 28, 2001. It seems that Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) kept using as if valid the power of attorney dated July 19, 2001 which was revoked on November 29, 2001.
I do not know the date when the account at UMB Bank NA was opened. However, if opened after November 29, 2001, the documentation used should have been fraudulent. If opened before November 29, 2001, it may seem that UMB Bank NA was deliberatively kept misinformed of the correct corporate structure of Pimjo Trust CV and its lawful representatives.
The possibility that this bizarre behaviors occurred in connection with UMB Bank NA, account number 26201338505041 is larger tan zero.
By information and belief, it seems that some letters might have been faked. The following is a letter dated in September 18, 1996 that, even though old, might support undue practices that were still in use even until 2011. The letter is signed by “Pimjo”. I believe that this practice may have been used up to 2011.
One punctuation of suspicion took place on November 2011, when Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) insisted and exerted pressure over me to incorporate my signature as an authorized signatory in account number A14-0505833-452 at Oppenheimer & Co., Inc. and to send him by email - without my signature - the information about wire transfers to be made and told me that he would execute them. This affirmation took place soon after having disclosed to me that no authorized signatories were registered in account number A14-0505833-452 at Oppenheimer & Co., Inc. .
Another punctuation occurred on February 24, 2012 during the meeting held at Oppenheimer & Co., Inc. offices in New York when Allen B. Holeman, Managing Director and Chief Compliance Officer of Oppenheimer & Co., Inc. (CRD # (1060910) expressed apologetically and disingenuously that they were not aware of any account with UMB Bank NA even though the check presented to them bore the logo of Oppenheimer.
Two inflection points arose during that meeting which are worth mentioning.
Oppenheimer & Co., Inc. New York Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) acknowledged and admitted that no attorney had reviewed the supporting documentation prepared and sent by Luis Alejandro Aguilar Pardo to Allen B. Holeman, Managing Director and Chief Compliance Officer of Oppenheimer & Co., Inc. (CRD # (1060910) while the latter made believe Luis Alejandro Aguilar Pardo that the delays were due to outside counsels ´reviews of the documentation. It became evident - and I complained bitterly about it - that none of the lawyers present at that meeting had reviewed the files. So much expression of mediocrity became evident after Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) promised to personally review the documentation which he never did. So, they plainly lied.
The second inflection point was that Allen B. Holeman, Managing Director and Chief Compliance Officer of Oppenheimer & Co., Inc. (CRD # (1060910) attitude was defensive and apologetic; frankly incoherent with the duties of his office. Instead of procuring certainty and searching for the true facts, he assumed the position of avoidance.
From then on, both Oppenheimer & Co., Inc. New York Executive Vicepresident and General Counsel Dennis P.McNamara (CRD # 2938486) and Allen B. Holeman, Managing Director and Chief Compliance Officer of Oppenheimer & Co., Inc. (CRD # (1060910) imposed a tactic of delays and avoidances.
Even though truth arrives at a slow pace, it must be pointed out that, as of Februray 9, 2012, had already received the letter from the exdirectors Redmond, Alfonzo and Toro. As it will be seen later on below, as of February 24, 2012, both Oppenheimer & Co., Inc. New York Executive Vicepresident and General Counsel Dennis P.McNamara (CRD # 2938486) and Allen B. Holeman, Managing Director and Chief Compliance Officer of Oppenheimer & Co., Inc. (CRD # (1060910) has had in their possession the
aforementioned letter for 16 days and deliberatively both concealed and lied above its existence. 6.- Failures of mandatory Anti-money laundering compliance programs and the effects of reincidence after John Gayle Pettus NYSE Hearing Board Decision 06-82 of June 27, 2006,
From information and belief Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) engaged in the very same activities for which he was penalized for under NYSE Hearing Board Decision 06-82 of June 27, 2006.
From information and belief, the NYSE Hearing Board - who did exercise powers of investigation which allegedly full jurisdiction upon Caracas Office Branch even when located in a foreign country and supposedly acting as independently owned local entity, failed to discover that the actions undertaken in the Caracas Branch Office were orchestrated for the purpose of actively participating in illegal foreign exchange transactions for several million of dollars perhaps and the anti-money laundering violations were intentionally part of the schema created to effectuate those illegal foreign exchange transactions among unrelated persons. The NYSE Hearing Board failed to ascertain that the operation of Oppenheimer & C., Inc. was secret, illegal, fictive, unregistered and unauthorized in clear violations of the laws of Repñublica Bolivariana de Venezuela.Perhaps, the possibility that the investigators of the Division of Enforcement from NYSE were relying on information contained in previously filed Form s10-K filed and the possibility that they were mislead by Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) were larger than zero.
I am afraid that “tainted money” might have traveled across those·transactions and made that point transparently and explicitly clear to the Oppenheimer & Co, Inc. directors and employees at the meeting of February 24, 2012. Of course, it is obvious that Oppenheimer & Co., Inc. New York Executive Vicepresident and General Counsel Dennis P.McNamara (CRD # 2938486) and Allen B. Holeman, Managing Director and Chief Compliance Officer of Oppenheimer & Co., Inc. (CRD # (1060910) were perfectly aware of Oppenheimer & Co., Inc. NYSE Hearing Board Panel Decision 05-181 dated December 29, 2005 and in John Pettus. NYSE Hearing Board Decision 06-82 dated June 27, 2006. On May 1, 2012, even under restriction, a wire transfer was attempted to be made under the initiative of New York Executive Vicepresident and General Counsel Dennis P.McNamara (CRD # 2938486) to several accounts.One of those accounts, for information and belief, was an account of a person who seems to be deceased since several years ago; perhaps on June 13, 1997.
From information and belief, itseems that the records of Pimjo Trust CV were deliberatively not updated for circa 11 years by Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) even though he was a director of Carisma Prima Limited and had actual knowledge of the characteristics of the corporate structure.
From information and belief, it seems that all transfers out of the account were either unsupported by letters from authorized signatories or supported by false letters.
The possibility of faking the signatures or using a facsimile with the signature oo an already deceased person is larger than zero.
From informationa and belief, it seems that the information concerning Pimjo Trust CV was deliberately kept wrong. It seems that the documentation concerning Pimjo Trust CV maintained in the files of Oppenheimer & Co., Inc. was that set of documents produced between July 19, 2001 and November 28, 2001. It seems that Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) kept using as if valid the power of attorney dated July 19, 2001 which was revoked on November 29, 2001. Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) signed the Unanimous Resolution of the Partners of Pimjo Trust CV dated November 29, 2001.
From information and belief, it seems that some letters authorizing wire transfers might have been faked by Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914).
Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) participated actively in the creation of Pimjo Trust CV and was aware of all changes which affected its corporate structure. He was aware that he lacked the power to represent Pimjo Trust CV. For information and belief, Oppenheimer & Co., Inc. Did profit for the creation of such entity. For information and belief, Amicorp International Ltd. Used to share revenue via commissions for clients referrals.
7.- Transactions performed without trading authorization.
I am only aware of one valid form issued to F. C. René Méndez de León falsely dated in New York on May 20, 2002, entitled “Trading Authorization Limited to Purchases and Sales of Securities and Commodities”.
I am not aware of any other trading authorization validly issued before May 20, 2012 and none was issued after the death of F. C. René Méndez de León. Sch an authorization would have required the signature of the undersigned and there are no records ofhavinf done so.
Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918) died on December 18, 2006.
8.- Money movements out of the account without authorization or registered signatory.
There are no records of any document ever granting authority to Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) to extract funds from the account or granting them signature powers for the accounts.
We fail to understand how extraction of funds was accomplished and what means were used.
9.- Opening and operating an account 26201338505041 at UMB Bank N.A. without authorization and authorized signatory.
There are no records of ever Pimjo Trust CV having authorized the opening and operation of the account 26201338505041 at UMB Bank N.A.
From information and belief, if Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) used the documentation created on July 19, 2001 (revoked on November 29, 2001) for the purposes of opening such account, it might be considered a fraudulent act to defraud Pimjo Trust CV, UMB Bank NA and Oppenheimer & Co., Inc.
10.- Concealing from Compliance Officers vital data of the client.
From information and belief, it seems that Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) intentionally concealed vital data about Pimjo Trust CV.
Once their powers of attorney were revoked on November 29, 2001,because the death of Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) were unable to represent Pimjo Trust CV and had the duty to report such facts to Oppenheimer & Co., Inc.
Furthermore, as directors of Carisma Prima Limited, they were fully aware of all changes and of the corporate structure to which Pimjo Trust CV belonged.
There is no credible explanation that during circa 11 years Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918),
Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) failed to report the existing corporate structure and failed to produce proper documentation for compliance purposes.
During those years, Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) managed to violate reporting requirements to the Internal Revenue Service for tax withholding purposes which endangered Pimjo Trust CV taxwise.
11.- Violation of conflict of interests rules and Code of Ethics.
From information and belief, Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) intentionally concealed from Oppenheimer & Co., Inc. their services as directors of Fundación Pimjo, A.C. and of Carisma Prima Limited.
If they effectively concealed such information and/or filed wrong FINRA UF forms, heir conduct was a clear violation of section 4. A. of Oppenheimer & Co., Inc. Code of Conduct and Business Ethics for Directors, Officers and Employees.
From information and belief, Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) intentionally misrepresented to Pimjo Trust CV that they were authorized to serve in the offices that they accepted.
12.- Intentional lack of KYC and compliance reviews.
From information and belief, Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) intentionally managed to avoid KYC and compliance reviews of Pimjo Trust CV. It is most disturbing that, having these entities been originally created by Oppenheimer & Co., Inc. and having actively participated in their activities, attorneys for Oppenheimer & Co., Inc. claim in their draft of their Interpleader Complaint the following:
“Considering the complex multi-national corporate structure which flows from the Pimjo Trust, Oppenheimer is unable to determine
which entity and/or individuals has the authority to instruct Oppenheimer with regard to the Account.” (Paragraph 26 of August 3, 2012 draft of Interpleader Complaint prepared by Satterlee Stephens Burke & Burke LLP).
13.- Illegal exercise of businesses in the financial sector in Venezuela without authorization.
Section 3. A. of Oppenheimer & Co., Inc. Code of Conduct and Business Ethics for Directors, Officers and Employees reads as follows:
“You must know, respect and comply with all laws, rules, and regulations applicable to the conduct of Oppenheimer's businesses in the areas in which you work. Oppenheimer actively promotes compliance with the laws, rules, and regulations that govern Oppenheimer's business. Obeying both the letter and spirit of the law is one of the foundations of Oppenheimer’s ethical standards. You must follow and obey the laws of all the states and countries where we operate. While you are not expected to be an expert on every detail of all the laws that govern our business in every jurisdiction, you are expected to understand the laws and regulations applicable to your duties at Oppenheimer and to understand the regulatory environment within which the firm operates well enough to know when to seek advice from your Manager, or the Legal and Compliance Departments. In addition there may be instances when you may want to consult a department head, or director or executive officer of Oppenheimer (each, a “Senior Officer”).
From information and belief, espite the declarations quoted above, Oppenheimer & Co., Inc.and other declarations contained in stated in Form 10-K filed for the fiscal year ended December 31, 2011 which are found below, as knowingly and intentionally violated the laws of Venezuela by usurping functions reserved by law to authorized entities.
Oppenheimer & Co., Inc. arrogated the function to participate without authorization, under cover and in secrecy in the securities sector and in the banking sector of Venezuela against clear rules of Venezuela public policy.
This section is devoted to violations of securities laws.
much in the way as Citibank, NA operates in Venezuela. But with substantial differences. While Citibank NA operates openly, legally and fully authorized and supervised as a registered branch of Citibank, NA, of New York, Umited States of America, Oppenheimer & Co., Inc. does it under the cover of a local entity named “Brisbane, Mendes de Leon, Pettus y Asociados, representantes de Oppenheimer & Co., Inc.”
As it will be seen later below, for information and belief, this is even in contradiction with what was disclosed in Form 10-K filed for the fiscal year ended December 31, 2011.
In accordance with Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) and Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486), “Brisbane, Mendes de Leon, Pettus y Asociados, representantes de Oppenheimer & Co., Inc.” is an authorized investment advisor in Venezuela by Superintendencia Nacional de Valores.
However, for information and belief, the reality is that “Brisbane, Mendes de Leon, Pettus y Asociados, representantes de Oppenheimer & Co., Inc.” is a fictive company used to cover up the activities of a full service broker-trader brokerage house offering and dealing with unregistered foreign securities within the internal market of Venezuela without authorization, supervision and controls even from Oppenheimer & Co., Inc. itself.
With due respect, from information and belief, Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch is a renegade and normally defecting operation out of control and supervision where normally prohibited behaviors seem to be the order of the day.
For information and belief, the main line of business of Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch does not constitute trading in Venezuela registered securities within Venezuela.
From information obtained from Bolsa de Valores de Caracas, it seems that neither Oppenheimer & Co., Inc., nor Fahnestock & Co., Inc. nor “Brisbane, Mendes de Leon, Pettus y Asociados, representantes de Oppenheimer & Co., Inc.” nor Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) are members of the Caracas Stock Exchange.
The current list of members of Bolsa de Valores de Caracas (Caracas Stock Exchange) are: Banacci Casa de Bolsa, C.A.
Valores Vencred Casa de Bolsa, S.A. Valores Occidentales Corporativos, C.A. Activalores Casa de Bolsa S.A.
Mercantil Merinvest, Casa de Bolsa, C.A.
Citibank Mercado de Capitales, C.a. (Citimerca) Asesora de Inversion y Casa de Bolsa Merge Capital Casa de Valores, C.a.
Cavelba Casa de Bolsa, S.A. Caja Caracas Casa de Bolsa, C.A. Inversiones Dundee C.A.
Interbursa Casa de Bolsa, C.A.
Financorp Valores Casa de Bolsa, C.A. Fivenca Casa de Bolsa, C.A.
Bfc Casa de Bolsa, C.A. Francisco Jose Briceño
Bod Valores Casa de Bolsa, C.A. Incorp Casa de Bolsa, S.A. Valcredi Casa de Bolsa, C.A. Provincial Casa de Bolsa, C.A. Victor Julio Flores Rojas Bernard Graham
Mario D´alfonso Schaffino Ecoplus Casa de Bolsa, C.A. Mercosur Casa de Bolsa, S.A. Corp Casa de Bolsa, C.A. 3intersec Casa de Bolsa, C.A. Edac Casa de Bolsa, C.A. Luis Alejandro Pulgar Corao Venevalores Casa de Bolsa, C.A. Sofimerca Casa de Bolsa, C.A.
Valores Santander Casa de Bolsa, C.A. Maximiza Casa de Bolsa, C.A.
Profesional Operador de Bolsa, C.A.
Interactivos Servicios Financieros Isf, Casa de Bolsa, C.A. Delsur, Inversiones 11022011, C.A.
Miguel Alfredo Calvo Behrens Corinvest Casa de Bolsa, C.A. Intertrust Asesoria Financiera, C.A. Manuel Alberto Alonso Rebareda
I.S.C. Invermercado Sociedad de Corretaje, C.A. Aida Devesa Latorre
Bencorpcap 20111, C.A. Bt Capital Casa de Bolsa, C.A. Bestinvest Casa de Bolsa C.A. B.n.h. Casa de Bolsa , C.A.
Globalcorp Casa de Bolsa S.A.
From information obtained from Superintendencia Nacional de Valores (National Superintendency of Securities) , it seems that neither Oppenheimer & Co., Inc., nor Fahnestock & Co., Inc. nor “Brisbane, Mendes de Leon, Pettus y Asociados, representantes de Oppenheimer & Co., Inc.” are authorized broker-dealers.
The current list of active broker - dealers registered with Superintendencia Nacional de Valores in Venezuela are:
Abaco Sociedad de Corretaje de Valores, C.A. Actimarket Sociedad de Corretaje de Valores, C.A. Actinvest Sociedad de Corretaje de Títulos Valores, C.A. Activalores Casa de Bolsa, S.A.
Banacci Casa de Bolsa, C.A. Bestinvest Casa de Bolsa, C.A. BFC Casa de Bolsa, C.A. BNH Casa de Bolsa, C.A.
Bod Valores Casa de Bolsa, C.A. BT Capital Casa de Bolsa, C.A. Caja Caracas Casa de Bolsa, C.A.
Capitalfin Sociedad de Corretaje de Títulos Valores, C.A.
Citibank Mercado de Capitales, C.A. (Citimerca) Asesora de Inversión y Casa de Bolsa Corinvest Casa de Bolsa, C.A.
Corp Casa de Bolsa, C.A.
Cuadra y Degwitz Casa de Bolsa, S.A. Ecoplus Casa de Bolsa, C.A.
Efincorp, Sociedad de Corretaje de Valores, C.A.
Fabesta, Estructuración y Asesoría Financiera Sociedad de Corretaje de Valores, S.A. Financorp Valores Casa de Bolsa, C.A.
Fivenca Casa de Bolsa, C.A.
GL4 Valores Sociedad de Corretaje, C.A.
Global Capital Valores Sociedad de Corretaje, C.A. Global Markets, C. A., Casa de Bolsa
Globalcorp Casa de Bolsa, S.A. Incorp Casa de Bolsa, C.A.
Interbono Sociedad de Corretaje de Valores, C.A. Interbursa Casa de Bolsa, C.A.
Intersec Casa de Bolsa, C.A.
Masvalor Sociedad de Corretaje de Valores, S.A. Maximiza Casa de Bolsa, C.A.
Mercantil Merinvest, Casa de Bolsa, C.A. Mercosur Casa de Bolsa, S.A.
Pablo Gonzalo Mercado de Capitales, C.A. Palogrande Casa de Bolsa, C.A.
Proinversion Sociedad de Corretaje de Titulos Valores, C.A. Provincial Casa de Bolsa, C.A.
Ratio Sociedad de Corretaje de Títulos Valores, C.A. Rendivalores Sociedad de Corretaje de Valores, C.A. Sequoian Sociedad de Corretaje de Valores, C.A. Solfin Sociedad de Corretaje de Valores, C.A. Suma Sociedad de Corretaje de Valores, C.A. U21 Casa de Bolsa, C.A. En Liquidación Ver Ficha Unitas Valores Sociedad de Corretaje de Valores, C.A. Valcredi Casa de Bolsa, C.A.
Valoralta Sociedad de Corretaje de Títulos Valores, C.A. Valores Santander Casa de Bolsa, C.A.
Valores Vencred Casa de Bolsa, C.A.
York Servicios Financieros Sociedad de Corretaje de Títulos Valores, C.A. Zafiro Valores Sociedad de Corretaje de Títulos Valores, C.A.
Zoom Sociedad de Corretaje de Valores, C.A.
From information and belief obtained from Superintendencia Nacional de Valores , it seems that Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) is not registered as broker-dealer in Venezuela.
The current list of active broker - dealers individuals registered with Superintendencia Nacional de Valores in Venezuela are:
Adaulfo Enrique Jiménez Landaeta Adelso González Socorro
Adriana Gutiérrez Gallegos Adriana Carolina Díaz Mendez Adriana Josefina Duarte Colina Aída Sofía Devesa Latorre Albert Detlev Schumacher Zibeil Alberto Benshimol Medina Alberto José Lucca Franceshi Alegría Benarroch Mahfoda Alejandro Sandoval Urosa Alejandro Pizzorni Guarnaschelli Alejandro Recio Pinto
Alejandro Abascal Rodulfo Alejandro Ignacio Cardot Escovar Alejandro José Oliveros Muñoz Alejandro Rafael Betancourt Matos Alfonso Manuel Angrisano Blank Alfredo Adrián Medina
Alfredo Enrique Bozo Cohen Alfredo José Larrazábal Delgado Alí Rafael Johnston Romero
Altina Mercedes De Sousa De Abreu América Mercedes Yánes Chacón Ana Karina Vásquez Parada Andrea Ramírez Beck Andrés González Clavelli Andrés Antonio Arráiz Santana Andrés José Vicentini Correa Angel Alberto Buenaño González Angel Alberto Peréz Serrano Angel Luis Pico Lagarda Antonio Rojas Segovia Antonio Javier D'elia Smith Antonio Jesús Dálbano Rivero Antonio José Golding Hernández Arelin Virginia Narvaez Duran Armando Delgado Rodríguez Armando Luis Grisanti Capriles Aurelio Laureano Useche Kislinger Bernardo José Pérez Romero Betzaida Thaís Villarroel Escalona Camilo Felipe Manrique Huizi Candelario José Lorbes Velazco Carla Regina Pedrós Rabasso Carlos Alberto Machado López Carlos Alejandro Vera Pérez Carlos Daniel González Bello Carlos Eduardo Maza Anduze Carlos Eduardo Rodríguez Castellvi Carlos Enrique Lippo Laporta Carlos Enrique Quintero Pérez Carlos José Acosta López
Carmelo Brucato Fruscione Carolina Muci Fernández
Christian Anthony De Veer Rodríguez Claudio Pecchio Vetencourth
Cosme Eduardo Betancourt Quarto Daniel Antero Nuñez Vasquez Daniel Jesús Nuñez Febres Daniel Simón Fermin Giménez David Alberto Rosales Romero Diana Iris Tulipano Martínez Diego Fernández Tinoco Diego Vicente Arnal Vallenilla Diógenes Augusto Sáenz Miranda Dolores María Rodríguez Bento Edda María González Bello Edgar Leonardo Nava Zambrano Eduardo Picón Iturriza
Eduardo Alberto Betancourt Frías Eduardo Simón Meinhard Zerpa Eleanor Arcia Jurado
Elisa Elvira París Casanova Emilio Antelo Rey
Enrique Lerner Rais
Enrique Antonio Maimone Leal Enrique Eduardo Rosal González Enrique Javier Zambrano Garriga Ernesto Antonio Hurtado Ubeda Felipe Aguerrevere Ruiz
Fernando Giordano Palancares Fernando Araujo Medina
Fernando José Mendoza Casanova Fortunato Benacerraf Saias Francisco García Fernández Francisco Arana Sanchez Francisco Fontiveros Francisco Zuñiga Robles Francisco Antonio Cabral Cruz Francisco José Briceño Corrales Freddy Alexis Zambrano Jiménez Freddy Jesús Mijares Aguilar Gabriel Guillermo Salas Ely
Gerardo José Serra Horobec Germán García Velutini
Gerónimo Alfredo Paolini García Gilberto José Varela Román Giorgio Giovanni Milani Fachinelli Gladys Elizabeth García Szuvajcer Graciela Rodríguez Sousa
Gregorio Tomassi González
Guillermo Benigno Montero González Gustavo Adán Medina Rosales
Gustavo Adolfo Martín Betancourt Álvarez Gustavo Alberto Hernández Pérez
Gustavo Antonio Lauria Romero Gustavo Antonio Marturet Medina Gustavo José Arenas
Gustavo Vladimir Pulido Medina Harry Oswaldo Carvajal Romero Helvio Jorge Sánchez Martínez Hernan José Sorate Orestes Humberto José Ramírez Urdaneta Ibrahim José Velutini Sosa
Ildefonso Augusto Gonzalez Aguilar Iván Antonio Márquez Bustamante Jesús Eduardo Herrera Hernández Jesús Nolberto Liendo Algarín Joaquín Emigdio Vera González Jorge Enrique Oquendo Reyes Jorge Luis Martínez Castro José Esayag Tendler
José Alfredo González Briceño José Antonio Miguez Fernández José Antonio Oliveros Febres Cordero José De Jesús Salvatierra Quintero José Félix Luzón Melo
José Gregorio Tineo Nottaro José Gregorio Rangel Fornez José Gregorio Hernández Hernández José Javier Valera Ventura
José Luis Falcón Mendoza José Luis Vethencourt D'elia José Rafael Fernandez Navarrete
José Ricardo Velasco Quintero Josepe Zeittouni
Juan Andrés Alamo Acedo Juan Andrés Mancera Basalo Juan Carlos Rangel González Juan Carlos Maldonado Bermúdez Juan Carlos Briquet Mármol Juan Domingo Pérez Esclusa Juan Domingo Cordero Marcano Juan Guillermo Otañez Ugueto Julia Beatríz Goncalves Mendes Julio César Pérez
Klaus Diethe Moreau Pardo Laura Josefina Pisani Siebert
Leonardo Antonio González Matamoros Leonardo Francisco Emperador Márquez Liberato Martucci Díaz
Luis Alejandro Pulgar Corao Luis Alfredo Farache Benacerraf Luis Andrés Navarrete Hanza Luis Eduardo Blanco
Luis Eduardo Baptista Zuloaga Luis Fernando Doza Villamizar Luís Fernando De Oteyza Pacanins Luis Guillermo Planas
Luis Guillermo Degwitz Brillembourg Luis Manuel Bulnes Muñoz
Luis María Cuadra Echeverría Luis Miguel Segovia Gonzalez Luisa Elena Vidaurre De Gomez Magaly Rainoa García
Manuel Martínez González Manuel Alberto Alonso Rebareda Manuel Angel Suena Cagiao
Manuel Eduardo Aranguren Aranguren Manuel Gonzalo Torres Gomez
Manuel Ricardo Baquero Méndez Marcelino Abascal Hernández Marco Fulvio Gasperini Gandino María Alexandra Dao Sarquis María Carolina Hernández González
Maria Milagros Andrade Briceño Marina Del Valle Lugo Peralta De Nava Mario D' Alfonso Schiaffino
Mario Alejandro Oliva Otero Mario José Montero Pardo Mario Roberto Simoza Carrasco
Marisela Coromoto Villavicencio Mendoza Maybe Madeleyne Quenza Arellano Mercurio Mario Bruno Colledanchise Michel Goguikian
Michele Paradiso
Miguel Alfredo Calvo Behrens Mónica Acosta Bond
Nelson Arenas
Nelson Alberto Corrie Soto Nestor Alberto Perez Hernandez Nestor José Noguera Manzanilla Nestor José Fernández García Noel Arturo Manzano Chirinos Nora Esperanza Buenaño Riera Omar Enrique Montesinos Ferrer Omar Enrique Nucete Velandia Orlando Josë Sthory Sosa Oscar Brito Rojas
Oscar Rubén Taylhardat García Oswaldo González Sanabria Oswaldo Enrique Rangel Oswaldo José Lairet Rodríguez Pablo Celio Gonzalo Aranda Pablo Emilio Gonzalo Dam Pedro Elías Cárdenas Pélaez Pedro Gustavo Ott Itriago Pedro Miguel Guedez López Pedro Pablo González Peña Rafael Díaz Casanova
Rafael Erasmo Osechas Melgarejo Rafael Eugenio Gill Ramirez Rais Meyer Malka
Raquel Costoya López
Raúl Enrique Maestres Useche Reinaldo Getulio Alvarez Cohén
Remberto Antonio Uzcátegui De La Cabada Renato Paulino Modernell Guerra
Ricardo Mariño Vega
Ricardo Martínez Maldonado Ricardo Iv Montilla Osorio Ricardo José Méndez Peña Ricardo José Arapé Rodríguez Ricardo José Larrazabal Vera Rogelio Andrés Cardozo Socorro Ronald Oscar Alemán Bali
Ronald Osias Rostoker Hubschman Ronnie Efrén Eidelman Solís Royden Roman Pico Martínez Samuel Levy Duer
Saúl Levine Seir
Sharim Karina Rubio Sheurich Tomas Fernando Montana Henríquez Tulio Jesús Bracho Méndez
Vicente Hernández García
Victor Eduardo Gonzalez Velandia Victor Julio Flores Rojas
Wendy Del Carmen Izarra Vivas Wilmer Leonel Estrada Ruiz
As it may observed from the following information obtained from Registro Nacional de Valores (National Registry of Securities), the company which seems to be registered and active is named Brisbane, Mendes de León & Asociados.
The information shows Norman J. Brisbane and Francois Mendes de León as “President”. Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) has no position or office. Rene F. C. Mendes de Leon died on December 18, 2006. I do not know the whereabouts of Norman J. Brisbane nor if Mr.Brisbane is still registered with any securirites agency within the United States of America.
From information and belief obtained from Superintendencia Nacional de Valores , it seems that Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) is not a registered investment advisor.
The current list of active investment advisor individuals registered with Superintendencia Nacional de Valores in Venezuela are:
Alonso José Rodríguez Segarra Aída Sofía Devesa Latorre Albert Detlev Schumacher Zibeil Alberto José Cárdenas Hernández Alejandro Recio Pinto
Alejandro Gabriel Salcedo Thielen Alexis Andrés Olivares Pulido Alfredo José Puerta Rodríguez Alix Margarita Ortega Aguilera Ana Laura González Gutierrez Andrés Chiodi Enrico
Andrés González Clavelli Andrés Antonio Arráiz Santana Angel David Alayon Peña Angel Rafael Rodríguez Grado Apolonia Barbara Marval Navarro Armando Delgado Rodríguez Armando Luis Grisanti Capriles
Arnoldo Prieto Domingo Van Bezooyen Piet Astrid Amaranta Arias Ruiz
Beatriz Elena Aleman Sánchez Belkis María Reyes Fernández Bernardo José Pérez Romero Candelario José Lorbes Velazco Carlo Cristoforo Lupini D'Aambrosio Carlos Eduardo Rodríguez Castellvi Carmelo Brucato Fruscione
Carmen Carolina Henríquez León Daniel Abreu Mendoza
Daniel Antonio Lahoud Carrero Daniela Carola Delgado Pérez Daniella Rachadell Contreras David Alberto Rosales Romero David Alejandro Tabernero Quintela
Diana Iris Tulipano Martínez Diógenes Augusto Sáenz Miranda Eccio Teodoro León Rodríguez Eduardo Picón Iturriza
Eduardo Alberto Betancourt Frías Eduardo Alfredo Vale Nieto Edwin Azael Escalona González Eleanor Arcia Jurado
Eligio César Peraza Huizi Enrique Lerner Rais Fortunato Benacerraf Saias Francisco José Briceño Corrales Freddy Alexis Zambrano Jiménez Freddy José Fiorillo De Freitas Giampiero Riccio Frojo
Gustavo Enrique Morales Briceño Gustavo Alberto Hernández Pérez Henrique Knotschke Larrazabal Ibrahim José Velutini Sosa Irene María Vilagut Vega Isabel Mercedes Pallarés Vivas Jacqueline Kannee De Alibert Jesuardo Eneas Areyán Salazar JesúsTadeo Prato Fontiveros Johny De Jesús Zafra Ramírez José Grasso Vecchio
José Oliveras Mesequer José Antonio Sucre Troconis José Esteban Pérez Montenegro José Gonzalo Muci Borjas José Tomás Carrillo Batalla José Antonio Courtois Matos José Antonio Miguez Fernández José Gregorio Tovar
José Guillermo De Pool Sánchez José Javier Llanos Mancisidor José Luis Falcón Mendoza José Raul Alegrett Ordoñez José Ricardo Velasco Quintero Josefina Lucía Baronetto Ricupero Juan Muci Muci
Juan Carlos Escotet Rodríguez Juan Domingo Cordero Marcano Juan Germann Ramírez Barráez Juliet Amalia Amado
Katharine Lucía Del Carmen Millán Méndez Klaus Diethe Moreau Pardo
Laila Luisa Galvez Bittar Leopoldo Enrique Ferris Wallis Luis Alberto Pérez Lavatelli Luis Alejandro Pulgar Corao Luis Alfredo Farache Benacerraf Luis Carlos Garrido Paulo
Manuel Alejandro Dopazo García Manuel Angel Suena Cagiao Manuel Antonio Gutiérrez Núñez Manuel Eduardo Aranguren Aranguren Marcel Ignacio Rodríguez Carvallo Marco Fulvio Gasperini Gandino María Eugenia Picón Carrillo Maria Adriana Nunes
María Elvira Novillo Díaz
María Inmaculada Carabaño Mele Marina Del Valle Lugo Peralta De Nava Mario Alejandro Oliva Otero
Marisabel José Marcano Vasquez Maura Pía Mulas Presi
Mauro Francisco Ferraro Perdomo Miguel Alberto García Díaz Mirca Ramona Lara Borges Nelly Parra Hernández
Noel Arturo Manzano Chirinos Oly Arlette Ball Ferrero
Orocio Eduardo Contasti Arosemena Oswaldo Enrique Rangel
Pedro Enrique Penzini López Pedro Gustavo Ott Itriago Ralph Howel Salazar Vilanova Raúl Armando Pérez Mollegas Raymond José Duarte Sandoval Roberto Rodríguez Vázquez Roberto Isasi Vantini
