Negative Materialism

SEALED SUPERSEDING INDICTMENT

S4 11 Cr. 205 (AKH)

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA

NICOLAS MADURO MOROS, DIOSDADO CABELLO RONDON, RAMON RODRIGUEZ CHACIN, CILIA ADELA FLORES DE MADURO, NICOLAS ERNESTO MADURO GUERRA,

a/k/a “Nicolasito,” a/k/a “The Prince,” and

HECTOR RUSTHENFORD GUERRERO FLORES,

a/k/a “Nifio Guerrero,”

Defendants.

The Grand Jury charges:

INTRODUCTION

For over 25 years, leaders of Venezuela have abused their positions of public trust

and corrupted once-legitimate institutions to import tons of cocaine into the United States.

NICOLAS MADURO MOROS, the defendant, is at the forefront of that corruption

and has partnered with his co-conspirators to use his illegally obtained authority and the

institutions he corroded to transport thousands of tons of cocaine to the United States. Since his

early days in Venezuelan government, MADURO MOROS has tarnished every public office he

has held. As a member of Venezuela’s National Assembly, MADURO MOROS moved loads of

cocaine under the protection of Venezuelan law enforcement. As Venezuela’s Minister of Foreign

Affairs, MADURO MOROS provided Venezuelan diplomatic passports to drug traffickers and

facilitated diplomatic cover for planes used by money launderers to repatriate drug proceeds from

Mexico to Venezuela. As Venezuela’s President and now-de facto ruler, MADURO MOROS

allows cocaine-fueled corruption to flourish for his own benefit, for the benefit of members of his

ruling regime, and for the benefit of his family members.

NICOLAS MADURO MOROS, the defendant, now sits atop a corrupt, illegitimate

government that, for decades, has leveraged government power to protect and promote illegal

activity, including drug trafficking. That drug trafficking has enriched and entrenched Venezuela’ s

political and military elite, including Minister of the Interior, Justice and Peace DIOSDADO

CABELLO RONDON, the defendant, and former Minister of the Interior and Justice RAMON

RODRIGUEZ CHACIN, the defendant. That massive-scale drug trafficking has also concentrated

power and wealth in the hands of MADURO MOROS ’ s family, including his wife, the purported

First Lady of Venezuela CILIA ADELA FLORES DE MADURO, the defendant, and MADURO

MOROS ’ s son, member of Venezuela’ s National Assembly NICOLAS ERNESTO MADURO

GUERRA, a/k/a “Nicolasito,” a/k/a “The Prince,” the defendant. This cycle of narcotics-based

corruption lines the pockets of Venezuelan officials and their families while also benefiting violent

narco-terrorists who operate with impunity on Venezuelan soil and who help produce, protect, and

transport tons of cocaine to the United States.

At various times since in or about 1999, Venezuelan officials, including NICOLAS

MADURO MOROS, DIOSDADO CABELLO RONDON, and RAMON RODRIGUEZ

CHACIN, the defendants, have partnered with narco-terrorists from the Fuerzas Armadas

Revolucionarias de Colombia (“F ARC”), Ejercito de Liberaci6n Nacional (“ELN”), the Sinaloa

Cartel, the Zetas, and Tren de Aragua (“TdA”), including TdA’ s

leader, HECTOR

RUSTHENFORD GUERRERO FLORES, a/k/a “Nifio Guerrero,” the defendant. In sum,

MADURO MOROS and his co-conspirators have, for decades, partnered with some of the most

violent and prolific drug traffickers and narco-terrorists in the world, and relied on corrupt officials

throughout the region, to distribute tons of cocaine to the United States.

THE DEFENDANTS

NICOLAS MADURO MOROS, the defendant, a Venezuelan citizen, was

previously the President of Venezuela, and is now, having remained in power despite losses in

recent elections, the de facto but illegitimate ruler of the country. MADURO MOROS also

previously held a seat in Venezuela’s National Assembly between in or about 2000 and in or about

2006, acted as the Venezuelan Minister of Foreign Affairs between in or about 2006 and in or

about 2013, and acted as the Vice President of Venezuela in or about 2013. MADURO MOROS

succeeded to the Venezuelan presidency after former President Hugo Chavez died in or about 2013

and, during MADURO MOROS’s own presidency, continued to participate in cocaine trafficking

with drug dealers and narco-terrorist groups. In or about 2018, MADURO MOROS declared

victory in a disputed and internationally condemned presidential election in Venezuela. In or about

2019, Venezuela’s National Assembly invoked the Venezuelan constitution and declared that

MADURO MOROS had usurped power and was not the legitimate President of Venezuela.

Nonetheless, MADURO MOROS continued to exercise the powers of the Venezuelan presidency,

causing more than 50 countries, including the United States, to refuse to recognize MADURO

MOROS as Venezuela’s head of state. In or about 2024, Venezuela held another presidential

election that was again widely criticized by the international community, in which MADURO

MOROS declared himself the winner despite widespread condemnation.

DIOSDADO CABELLO RONDON, the defendant, a Venezuelan citizen, is the

Minister of the Interior, Justice and Peace, a member of the Venezuelan armed forces, and the Vice

President of the ruling United Socialist Party of Venezuela. CABELLO RONDON is widely

recognized as one of the most powerful officials in Venezuela. CABELLO RONDON previously

acted as Chief of Staff to Chavez in or about 2001, Vice President of Venezuela in or about 2002,

Governor of Venezuela’ s Miranda State between in or about 2004 and in or about 2008, and

President of Venezuela’ s National Assembly between in or about 2012 and in or about 2016.

Between in or about 2017 and in or about 2020, CABELLO RONDON acted as a member and

then President of Venezuela’ s National Constituent Assembly, following the illegitimate creation

of the National Constituent Assembly, which siphoned the constitutional powers of Venezuela’ s

National Assembly and further entrenched MADURO MOROS ’s regime. Following the

dissolution of the National Constituent Assembly in or about 2020, CABELLO RONDON became

a member of Venezuela’ s National Assembly between in or about 2021 and in or about 2024.

RAMON RODRJGUEZ CHACIN, the defendant, is a Venezuelan politician and

former member of the armed forces, who served as the Minister of the Interior and Justice between

in or about 2002 and 2008. Between in or about 2012 and in or about 2017, RODRJGUEZ

CHACiN was the Governor of Venezuela’s Guarico State.

CILIA ADELA FLORES DE MADURO, the defendant, is the de facto First Lady

of Venezuela, having married NICOLAS MADURO MOROS, the defendant, in or about 2013.

FLORES DE MADURO has had a longstanding political career. FLORES DE MADURO has

acted as the President of the National Assembly (starting when MADURO MOROS left that role

to become Minister of Foreign Affairs) between in or about 2006 and in or about 2011 , as the

Attorney General of Venezuela between in or about 2012 and in or about 2013, and as a member

of the National Constituent Assembly starting in or about 2017.

NICOLAS ERNESTO MADURO GUERRA, a/k/a “Nicolasito,” a/k/a “The

Prince,” the defendant, is the son of NICOLAS MADURO MOROS, the defendant, and a corrupt

Venezuelan politician. MADURO GUERRA entered politics after his father, MADURO MOROS,

became the President of Venezuela in or about 2013. At that time, MADURO MOROS appointed

MADURO GUERRA the “Head of the Corps of Special Inspectors of the Presidency,” a position

which was created for MADURO GUERRA. In or about 2017, MADURO GUERRA entered

Venezuela’ s National Constituent Assembly, and in or about January 2021 , MADURO GUERRA

entered Venezuela’ s National Assembly, where he continues to hold office.

HECTOR RUSTHENFORD GUERRERO FLORES, a/k/a “Nifio Guerrero,” the

defendant, has, for over a decade, served as either the leader or co-leader of TdA, during which

time TdA members and associates have engaged in a wide range of crimes, including extortions,

kidnappings, murders, drug trafficking, gun trafficking, prostitution, sex trafficking, robberies,

bank burglaries, and money laundering in Venezuela, the United States, and elsewhere.

THE NARCO-TERRORIST ORGANIZATIONS WORKING IN PARTNERSHIP WITH THE DEFENDANTS

The FARC, since its founding in 1964, has become one of the largest producers of

cocaine in the world. The F ARC has generated significant revenue through its cocaine trafficking,

which it used to fund its operations, including, for example, large-scale weapons purchases and

terrorist attacks. The F ARC has also directed violent acts against United States persons and

property in foreign jurisdictions, including, but not limited to, Colombia. For example, from at

least in or about 2003 to in or about 2008, F ARC leadership ordered F ARC members to kidnap

and murder United States citizens and to attack United States interests in order to dissuade the

United States from continuing its efforts to fumigate and disrupt the FARC’s manufacturing and

distribution of cocaine and cocaine paste. Consistent with these activities, in or about 1997, the

U.S. Department of State (“State Department”) designated the F ARC as a foreign terrorist

organization (“FTO”) pursuant to Section 219 of the Immigration and Nationality Act (“INA”).

On November 30, 2021 , the State Department removed the FARC from the FTO list and

simultaneously designated two F ARC successor organizations as FTOs pursuant to Section 219 of

the INA: the F ARC-EP and Segunda Marquetalia, both of which remain so designated as of the

filing of this Superseding Indictment.

The ELN has operated as a Colombian terrorist group since 1965, dedicated to the

violent overthrow of the democratically elected government of Colombia. In furtherance of its

anti-government agenda, the ELN has committed kidnappings, bombings, and other violent attacks

targeting civilians and Colombian law enforcement. In addition, the ELN exports tons of cocaine

annually to the United States and elsewhere in order to finance its terrorist activities, and has, at

various times, partnered with other Colombian guerilla groups in pursuit of its cocaine trafficking

and violent agenda. Consistent with these activities, in or about 1997, the State Department

designated the ELN as an FTO pursuant to Section 219 of the INA. ELN remains so designated as

of the filing of this Superseding Indictment.

The Sinaloa Cartel, based in the Mexican state of Sinaloa, has its roots in the late

1980s, when the so-called Mexican Federation functioned as a council with representatives from

the respective drug trafficking organizations of its principal leaders. During the late 1980s and

1990s, the members of the Mexican Federation partnered with Colombian sources of supply to

transport drugs through Mexico and into the United States. In the early 2000s, Joaquin Archivaldo

Guzman Loera, a/k/a “El Chapo,” and Ismael Zambada Garcia, a/k/a “El Mayo,” formed a

partnership that led to transformation of the Mexican Federation into the Sinaloa Cartel, which

became the largest drug trafficking organization in the world. At present, the Sinaloa Cartel is

highly organized and active in more than half of all states in Mexico. Through a sophisticated and

heavily armed security apparatus, the Sinaloa Cartel wields power through fear, threats, and

violence, including by killing police, civilians, and members of other criminal groups who

encroach on their territory without authorization. Members of the Sinaloa Cartel may also be killed

for perceived disloyalty, disobedience, or to send a message. To further and protect its drug

interests, the Sinaloa Cartel engages in other criminal conduct, including bribery, extortion, and

weapons trafficking. As an additional means of revenue and profit, the Sinaloa Cartel engages in

migrant smuggling and human trafficking. Consistent with these activities, in or about February

2025, the State Department designated the Sinaloa Cartel as an FTO pursuant to Section 219 of

the INA. The Sinaloa Cartel remains so designated as of the filing of this Superseding Indictment.

The Zetas, later known as the Cartel def Noreste (“CDN”), is a violent and prolific

transnational drug organization based in northeastern Mexico involved in drug trafficking,

kidnapping, extortion, human smuggling, and other illicit activities. The Zetas use violence to exert

criminal control, including attacks against government officials in Mexico. Between in or about

2000 and in or about 2010, the Zetas formed an alliance with the Gulf Cartel, a group of drug

traffickers primarily based in northern Mexico, whereby the Zetas served as the armed militaristic

wing of the Gulf Cartel to maintain control of drug trafficking routes throughout Mexico. The

Zetas recruited members of the Mexican special forces, along with drug traffickers who never

served in the military or with a police force, to join the organization. In or about the summer of

2010, the Zetas and Gulf Cartel’ s alliance fractured, after a period of intense violence between the

organizations. At that time, the Zetas operated as an independent drug trafficking organization that

imported ton-quantities of cocaine to the United States. Consistent with these activities, in or about

February 2025, the State Department designated CDN, formerly known as the Zetas, as an FTO

pursuant to Section 219 of the INA. CDN (referred to as the “Zetas” in this Superseding

Indictment) remains so designated as of the filing ofthis Superseding Indictment.

TdA is a violent transnational criminal organization that originated as a prison gang

in Venezuela. TdA has expanded its criminal network throughout the Western Hemisphere and

established a presence in the United States, including New York. Td.A’s criminal activities include

human smuggling and other illicit acts. TdA has developed additional revenue sources through a

range of other criminal activities, including drug trafficking, firearms trafficking, commercial sex

trafficking, kidnapping, robbery, theft, fraud, and extortion. TdA members also commit murder,

assault, and other acts of violence to enforce and further the organization’ s criminal activities. TdA

has formed ties with other criminal groups operating in the Western Hemisphere and, at times, is

willing to collaborate with other criminal groups and organizations on a local and ad hoc basis.

Consistent with these activities, in or about February 2025, the State Department designated TdA

as an FTO pursuant to Section 219 of the INA. TdA remains so designated as of the filing of this

Superseding Indictment.

THE DEFENDANTS’ CORRUPT DRUG TRAFFICKING AND CONNECTIONS TO NARCO-TERRORIST GROUPS

NICOLAS MADURO MOROS, the defendant-like former President Chavez

before him-participates in, perpetuates, and protects a culture of corruption in which powerful

Venezuelan elites enrich themselves through drug trafficking and the protection of their partner

drug traffickers. The profits of that illegal activity flow to corrupt rank-and-file civilian, military,

and intelligence officials, who operate in a patronage system run by those at the top-referred to

as the Cartel de Los Soles or Cartel of the Suns, a reference to the sun insignia affixed to the

uniforms of high-ranking Venezuelan military officials.

Venezuela sits in a geographically valuable location for drug traffickers, with

northern access to the Caribbean Sea via several large ports and western access to the mountainous

regions of Colombia, where coca is grown and turned into the vast majority of the world’s cocaine

supply in jungle laboratories. Starting in or about 1999, Venezuela became a safe haven for drug

traffickers willing to pay for protection and support corrupt Venezuelan civilian and military

officials, who operated outside the reach of Colombian law enforcement and armed forces

bolstered by United States anti-narcotics assistance.

In that environment, cocaine trafficking flourished. Venezuelan officials and their

family members-including NICOLAS MADURO MOROS, DIOSDADO CABELLO

RONDON, RAMON RODRIGUEZ CHACIN, CILIA ADELA FLORES DE MADURO, and

NICOLAS ERNESTO MADURO GUERRA, a/k/a “Nicolasito,” a/k/a “The Prince,” the

defendants-partnered with narcotics traffickers and narco-terrorist groups, who dispatched

processed cocaine from Venezuela to the United States via transshipment points in the Caribbean

and Central America, such as Honduras, Guatemala, and Mexico. By in or about 2020, the State

Department estimated that between 200 and 250 tons of cocaine were trafficked through Venezuela

annually. The maritime shipments were shipped north from Venezuela’ s coastline using go-fast

vessels, fishing boats, and container ships. Air shipments were often dispatched from clandestine

airstrips, typically made of dirt or grass, and also from commercial airports under the control of

corrupt government and military officials.

Through this drug trafficking, NICOLAS MADURO MOROS, the defendant, and

corrupt members of his regime enabled corruption fueled by drug trafficking throughout the

region. The transshipment points in Honduras, Guatemala, and Mexico similarly relied on a culture

of corruption, in which cocaine traffickers operating in those countries paid a portion of their own

profits to politicians who protected and aided them. In turn, these politicians used the cocaine

fueled payments to maintain and augment their political power. So, too, were politicians along the

“Caribbean route” corrupted by cocaine traffickers, who would pay them for protection from arrest

and to allow favored traffickers to operate with impunity as they trafficked cocaine from Venezuela

north towards the United States. Thus, at every step–relying on the producers in Colombia,

transporters and distributors in Venezuela, and recipients and re-distributors on transshipment

points north-the traffickers enriched themselves and their corrupt benefactors who protected and

aided them.

Similarly, NICOLAS MADURO MOROS, DIOSDADO CABELLO RONDON,

RAMON RODRIGUEZ CHACIN, the defendants, and other corrupt members of the regime

facilitated the empowerment and growth of violent narco-terrorist groups fueling their

organizations with cocaine profits. These narco-terrorist organizations not only worked directly

with and sent profits to high-ranking Venezuelan officials, but also reaped the benefits of the

increased value of that cocaine at each transshipment point along the way to the United States,

where demand and thus the price of cocaine is highest. Those organizations include the F ARC and

ELN, which control cocaine production in the mountainous regions of Colombia; the Sinaloa

Cartel and Zetas, which control routes in Central America and the methods for crossing cocaine

from Mexico into the United States; and TdA, which controls a criminal network able to assist

with the transportation of cocaine within Venezuela and on the Venezuelan coast.

OVERT ACTS IN FURTHERANCE OF THE DEFENDANTS’ DRUG TRAFFICKING AND NARCO-TERRORISM CONSPIRACIES

The defendants, together and with others, engaged in a relentless campaign of

cocaine trafficking throughout the time period charged in this Superseding Indictment, resulting

in the distribution of thousands of tons of cocaine to the United States. Throughout, NICOLAS

MADURO MOROS, the· defendant, along with members of his family and other corrupt officials,

provided law enforcement cover and logistical support for the transport of cocaine through

Venezuela, with knowledge that their drug trafficking partners would move the cocaine north to

the United States. While this conduct occurred regularly and repeatedly throughout the time period

charged, below are certain examples of acts engaged in by the defendants in furtherance of their

drug trafficking, including in partnership with narco-terrorist groups:

Between approximately 2006 and 2008, while acting as Venezuela’ s

Minister of Foreign Affairs, MADURO MOROS sold Venezuelan diplomatic passports to

individuals that MADURO MOROS knew were drug traffickers in order to assist traffickers

seeking to move drug proceeds from Mexico to Venezuela under diplomatic cover. When the drug

traffickers needed to move drug proceeds from Mexico back to Venezuela, MADURO MOROS

facilitated the movement of private planes under diplomatic cover to ensure the flights received no

scrutiny from law enforcement or the military. On these occasions, MADURO MOROS called the

Venezuelan embassy in Mexico to advise that a diplomatic mission would be arriving by private

plane. Then, while the traffickers met with the Venezuelan Ambassador to Mexico under the

auspices of a diplomatic mission from MADURO MOROS, their plane was loaded with the drug

proceeds. The plane would then return to Venezuela under diplomatic cover.

In approximately 2007, CILIA ADELA FLORES DE MADURO, the

defendant, attended a meeting in which FLORES DE MADURO accepted hundreds of thousands

of dollars in bribes to broker a meeting between a large-scale drug trafficker and the director of

Venezuela’s National Anti-Drug Office, Nestor Reverol Torres. The drug trafficker later arranged

to pay a monthly bribe to Reverol Torres, in addition to approximately $100,000 for each flight

that was transporting cocaine to ensure the flight’s safe passage, a portion of which was then paid

to FLORES DE MADURO. In or about 2015, Reverol Torres was charged with narcotics offenses

in the Eastern District of New York and is a fugitive.

Between in or about 2003 and in or about 2011, while DIOSDADO

CABELLO RONDON, the defendant, occupied various official positions in Venezuela, the Zetas

worked with a group of Colombian drug traffickers to dispatch cargo containers on container ships

carrying five to six tons of cocaine each, and sometimes as much as 20 tons each, from ports in

Venezuela to ports in Mexico, and ultimately to the United States. The tens of thousands of

kilograms of cocaine sent by this group were protected in Venezuela by Venezuelan military

officials referred to as “the generals.”

Between in or about 2004 and in or about 2015, MADURO MOROS and

FLORES DE MADURO worked together to traffic cocaine, much of which had been previously

seized by Venezuelan law enforcement, with the assistance of armed military escorts. During this

time, MADURO MOROS and FLORES DE MADURO maintained their own groups of state

sponsored gangs known as colectivos to facilitate and protect their drug trafficking operation.

MADURO MOROS and FLORES DE MADURO also ordered kidnappings, beatings, and

murders against those who owed them drug money or otherwise undermined their drug trafficking

operation, including ordering the murder of a local drug boss in Caracas, Venezuela.

In or about 2006, Venezuelan officials dispatched more than 5.5 tons of

cocame from Venezuela to Mexico on a DC-9 jet. CABELLO RONDON; then-director of

Venezuela’s military intelligence agency, Hugo Armando Carvajal Barrios, a/k/a “El Pollo,” who,

in June 2025, pled guilty in this District to the narco-terrorism, narcotics, and weapons offenses in

the First Superseding Indictment in this case, Sl 11 Cr. 205 (AKH); and Venezuelan National

Guard Captain Vassyly Kotosky Villarroel Ramirez worked with other members of the

Venezuelan regime to coordinate the shipment. The more than 5 .5 tons of cocaine were transported

in approximately five vans to the hangar reserved for the Venezuelan president at Simon Bolivar

International Airport in Maiquetia, Venezuela ( the “Maiquetia Airport”). At the Maiquetia Airport,

members of the Venezuelan National Guard loaded the cocaine onto the plane, which took off

using a flight plan that Villarroel Ramirez approved in exchange for bribes. Despite the payment

of those bribes, when the plane landed at Ciudad del Carmen Airport in Campeche, Mexico,

Mexican authorities seized more than 5.5 tons of cocaine. Shortly after the seizure, Villarroel

Ramirez told the Venezuelan drug traffickers who worked with him that they needed to pay

CABELLO RONDON a bribe to ensure that those who had assisted them at the Maiquetia Airport

would not be arrested. Villarroel Ramirez then arranged a meeting with CABELLO RONDON,

after which the traffickers paid approximately $2,500,000 to CABELLO RONDON through his

family member. In or about 2013, Villarroel Ramirez was charged with narcotics offenses in the

Eastern District of New York and is a fugitive.

Between approximately 2006 and 2008, HECTOR RUSTHENFORD

GUERRERO FLORES, a/k/a “Nifio Guerrero,” the defendant, worked with one of the largest drug

traffickers in Venezuela, Walid Makled. Members of the Venezuelan regime helped protect

Makled’s cocaine shipments that were transported from San Fernando de Apure, Venezuela, to

Valencia, Venezuela, and were then sent by plane from the Valencia international airport to

Mexico and other locations in Central America for eventual distribution to the United States.

Between in or about 2008 and in or about 2009, GUERRERO FLORES also provided another

major Venezuelan drug trafficker with protection for cocaine shipments moving through

Venezuela, including by providing armed men who carried, among other automatic weapons, AK-

47s, MP5s, and AR-15s, as well as grenades. At times, GUERRERO FLORES personally

accompanied large cocaine loads as they were guarded by the teams of armed men, en route to

airports or airstrips for transport north and eventual distribution to the United States. GUERRERO

FLORES was paid a fee per kilogram of cocaine transported or received and he sometimes

received an interest in portions of these massive cocaine shipments in lieu of payment. The

traffickers that GUERRERO FLORES worked with moved thousands of kilograms per shipment,

multiple times per month, resulting in the distribution of hundreds of tons of cocaine to the United

States. In or about 2009, Makled was charged with narcotics offenses in this District and is a

fugitive.

In or about 2008, RAMON RODRIGUEZ CHACIN, the defendant,

maintained a large estate in Barinas State, Venezuela, which contained a large F ARC encampment

and training school, with approximately 200 armed F ARC members carrying automatic rifles at

any given time. During this time, RODRIGUEZ CHACiN accepted tens of thousands of dollars

in bribes to use his corrupt influence to shield a large-scale drug trafficker from arrest and

extradition. During subsequent meetings with the drug trafficker between in or about 2008 and in

or about 2010, RODRIGUEZ CHACiN discussed trafficking multi-ton quantities of cocaine with

other Venezuelan officials, including Carvajal Barrios.

In or about 2011, the Sinaloa Cartel’s then-leader, Joaquin Archivaldo

Guzman Loera, a/k/a “El Chapo,” financed cocaine laboratories in Colombia. Cocaine produced

in those laboratories was then transported under the protection of the F ARC into Venezuela, and

received protection en route to an airstrip from Carvajal Barrios, a close ally of MADURO

MOROS and CABELLO RONDON.

In or about September 2013, mere months after MADURO MOROS

succeeded to the Venezuelan presidency, Venezuelan officials dispatched approximately 1.3 tons

of cocaine on a commercial flight from the Maiquetia Airport to Paris Charles de Gaulle Airport.

French authorities seized the cocaine. Following the seizure, MADURO MOROS convened a

meeting with, among others, CABELLO RONDON and Carvajal Barrios. During the meeting,

MADURO MOROS told CABELLO RONDON and Carvajal Barrios that they should not have

used the Maiquetia Airport for drug trafficking after the 2006 seizure in Mexico, and that they

should instead use other well-established drug routes and locations to dispatch cocaine. Shortly

thereafter, MADURO MOROS and others authorized the arrests of certain Venezuelan military

officials in an effort to divert public and law enforcement scrutiny away from MADURO

MOROS’s, CABELLO RONDON’s, and Carvajal Barrios’s participation in the shipment and its

coverup.

Between approximately 2014 and 2015, a captain m the Venezuelan

National Guard on Margarita Island, Venezuela, coordinated hotels, transportation, women, and

food for visits by Venezuelan officials, including NICOLAS ERNESTO MADURO GUERRA,

a/k/a “Nicolasito,” a/k/a “The Prince,” the defendant, who visited Margarita Island approximately

twice monthly. MADURO GUERRA would arrive on a Falcon 900 plane owned by Venezuela’s

state oil company, Petr6leos de Venezuela, S.A. (“PDVSA”). Before leaving the island,

MADURO GUERRA’s PDVSA plane would be loaded, sometimes with the assistance of armed

sergeants, with large packages wrapped in tape that the captain understood were drugs. MADURO

GUERRA was present while the PDVSA plane was loaded and, on one occasion, stated that the

plane could go wherever it wanted, including the United States.

Between in or about October 2015 and in or about November 2015, Efrain

Campo Flores and Franqui Francisco Flores de Freitas-two relatives of MADURO MOROS and

FLORES DE MADURO-agreed during recorded meetings with DEA confidential sources to

dispatch multi-hundred-kilogram cocaine shipments from MADURO MOROS’s “presidential

hangar” at the Maiquetia Airport. During recorded meetings with the sources, Campo Flores and

Flores de Freitas explained that they were at “war” with the United States, described the Cartel de

Los Soles, discussed a connection to a “commander for the F ARC” who was “supposedly high-

ranked,” and indicated that they were seeking to raise $20 million in drug proceeds to support a

campaign by FLORES DE MADURO in connection with a late-2015 election for the Venezuelan

National Assembly. Campo Flores referred to MADURO MOROS as his “father,” and stated that

“what we want is for him to take control again of the … National Assembly.” In or about

November 2016, Campo Flores and Flores de Freitas were convicted at trial in this District of

conspiring to import cocaine into the United States.

In or about 201 7, MADURO GUERRA worked to ship hundreds of

kilograms of cocaine from Venezuela to Miami, Florida. During this time, MADURO GUERRA

spoke with his drug trafficking partners about, among other things, shipping low-quality cocaine

to New York because it could not be sold in Miami, arranging a 500-kilogram shipment of cocaine

to be unloaded from a cargo container near Miami, and using scrap metal containers to smuggle

cocaine into the ports of New York.

In or about 2018 and 2019, RODRIGUEZ CHACIN made multiple trips

from Barinas State to Caracas with a key F ARC leader for meetings with MADURO MOROS.

These trips were part of a long history of RODRIGUEZ CHACIN’ s regular meetings with F ARC

and ELN members in both their jungle encampments and Barinas because RODRIGUEZ CHACIN

was assigned by MADURO MOROS to provide the F ARC and ELN with protection and support.

RODRIGUEZ CHACIN also brought F ARC leaders to meet MADURO MOROS at Miraflores,

the presidential palace in Caracas, as well as at Fuerte Tiuna, the chief military complex in Caracas

and headquarters of Venezuela’s Ministry of Defense.

In or about July 2019, shortly after certain FARC leaders had publicly

returned to arms despite the signing of recent peace accords with the Colombian government,

MADURO MOROS and CABELLO RONDON attended a videotaped press conference at which

MADURO MOROS announced that the F ARC and its leaders were welcome in Venezuela.

In or about 2019, TdA’ s leader, GUERRERO FLORES, discussed drug

trafficking with an individual he understood to be working with the Venezuelan regime. Over

multiple calls, GUERRERO FLORES offered to provide escort services for drug loads, explaining

that GUERRERO FLORES and TdA had control of the coastlines of Venezuela’s Aragua State.

GUERRERO FLORES, speaking from TdA’ s base of operations in Tocor6n Prison, explained that

TdA could handle the logistics of every aspect of the drug trade, including the use of storage

compartments that GUERRERO FLORES called “cradles” located on a beach in Aragua State. In

doing so, GUERRERO FLORES confirmed TdA’ s ability to protect over one ton of cocaine.

In or about 2020, MADURO GUERRA attended a meeting in Medellin,

Colombia, with two representatives of the F ARC. During the meeting, MADURO GUERRA

discussed arrangements to move large quantities of cocaine and weapons through Colombia and

into the United States over the course of the next six years, until in or about 2026. MADURO

GUERRA also discussed paying the F ARC with weapons in connection with the cocaine loads.

In or about 2007, at the direction of Carvajal Barrios, Venezuelan General

Cliver Alcala Cordones delivered to F ARC leadership four crates of weapons from the Venezuelan

Government, which included 20 grenades and two grenade launchers. In or or about June 2023,

Alcala Cordones pled guilty in this District to conspiring to provide material support to the F ARC,

an FTO, pursuant to the Third Superseding Information in this case, S3 11 Cr. 205 (AKH).

Between in or about 2022 and in or about 2024, CABELLO RONDON

regularly traveled to clandestine airstrips controlled by the ELN near the Colombia-Venezuela

border to ensure the cocaine’ s continued safe passage in Venezuelan territory. From these airstrips,

cocaine was dispatched out of Venezuela both on flights approved by Venezuelan military officials

and on clandestine flights designed to avoid detection by law enforcement or militaries in South

and Central America.

In or about the end of 2024, CABELLO RONDON received narcotics

proceeds from cocaine trafficking, and in or about 2025, Colombian drug traffickers discussed

with an associate of CABELLO RONDON plans for continued cocaine trafficking through

Venezuela.

STATUTORY ALLEGATIONS

COUNT ONE (Narco-Terrorism Conspiracy)

Paragraphs 1 through 21 of this Superseding Indictment are realleged and

incorporated by reference as though fully set forth herein.

From at least in or about 1999, up to and including in or about 2025, in an offense

begun and committed out of the jurisdiction of any particular State or district of the United States,

NICOLAS MADURO MOROS, DIOSDADO CABELLO RONDON, and RAMON

RODRIGUEZ CHACIN, the defendants, and others known and unknown, at least one of whom

has been and will be first brought to and arrested in the Southern District of New York,

intentionally and knowingly combined, conspired, confederated, and agreed together and with

each other to violate Title 21 , United States Code, Section 960a.

It was a part and an object of the conspiracy that NICOLAS MADURO MOROS,

DIOSDADO CABELLO RONDON, and RAMON RODRIGUEZ CHACIN, the defendants, and

others known and unknown, would and did engage in conduct that would be punishable under

Title 21 , United States Code, Section 841 ( a), if committed within the jurisdiction of the United

States, to wit, the distribution of, and possession with the intent to distribute, five kilograms and

more of mixtures and substances containing a detectable amount of cocaine, knowing and

intending to provide, directly and indirectly, something of pecuniary value to a person and

organization that has engaged and engages in terrorism and terrorist activity (as defined in Title 8,

United States Code, Section 1182(a)(2)(B)), or terrorism (as defined in Title 22, United States

Code, Section 2656f(d)(2)), to wit, the following organizations that have been designated by the

United States Secretary of State as FTOs pursuant to Section 219 of the INA, during times relevant

to this Superseding Indictment: FARC, FARC-EP, Segunda Marquetalia, ELN, TdA, the Sinaloa

Cartel, CDN, also known as the Zetas, and each organization’s members, operatives, and

associates, having knowledge that such organizations and persons have engaged and engage in

terrorist activity and terrorism, in violation of Title 21, United States Code, Section 960a.

(Title 21, United States Code, Section 960a; and Title 18, United States Code, Section 3238.)

COUNT TWO (Cocaine Importation Conspiracy)

The Grand Jury further charges:

Paragraphs 1 through 21 of this Superseding Indictment are realleged and

incorporated by reference as though fully set forth herein.

From at least in or about 1999, up to and including in or about 2025, in an offense

begun and committed out of the jurisdiction of any particular State or district of the United States,

NICOLAS MADURO MOROS, DIOSDADO CABELLO RONDON, RAMON RODRIGUEZ

CHACIN, CILIA ADELA FLORES DE MADURO, NICOLAS ERNESTO MADURO

GUERRA, a/k/a “Nicolasito,” a/k/a “The Prince,” and HECTOR RUSTHENFORD GUERRERO

FLORES, a/k/a “Nifio Guerrero,” the defendants, and others known and unknown, at least one of

whom has been and will be first brought to and arrested in the Southern District of New York,

intentionally and knowingly combined, conspired, confederated, and agreed together and with

each other to violate provisions of Title 21 , United States Code, Chapter 13, Subchapter II.

It was a part and an object of the conspiracy that NICOLAS MADURO MOROS,

DIOSDADO CABELLO RONDON, RAMON RODRIGUEZ CHACIN, CILIA ADELA

FLORES DE MADURO, NICOLAS ERNESTO MADURO GUERRA, a/k/a “Nicolasito,” a/k/a

“The Prince,” and HECTOR RUSTHENFORD GUERRERO FLORES, a/k/a “Nino Guerrero,”

the defendants, and others known and unknown, would and did knowingly and intentionally import

into the United States from a place outside thereof a controlled substance, in violation of Title 21 ,

United States Code, Sections 952(a) and 960(a)(l).

It was further a part and an object of the conspiracy that NICOLAS MADURO

MOROS, DIOSDADO CABELLO RONDON, RAMON RODRIGUEZ CHACIN, CILIA

ADELA FLORES DE MADURO, NICOLAS ERNESTO MADURO GUERRA, a/k/a

“Nicolasito,” a/k/a “The Prince,” and HECTOR RUSTHENFORD GUERRERO FLORES, a/k/a

“Nino Guerrero,” the defendants, and others known and unknown, would and did manufacture,

distribute, and possess with intent to distribute a controlled substance, intending, knowing, and

having reasonable cause to believe that such substance would be unlawfully imported into the

United States and into waters within a distance of 12 miles of the coast of the United States, in

violation of Title 21 , United States Code, Sections 959(a) and 960(a)(3).

It was further a part and an object of the conspiracy that NICOLAS MADURO

MOROS, DIOSDADO CABELLO RONDON, RAMON RODRIGUEZ CHACIN, CILIA

ADELA FLORES DE MADURO, NICOLAS ERNESTO MADURO GUERRA, a/k/a

“Nicolasito,” a/k/a “The Prince,” and HECTOR RUSTHENFORD GUERRERO FLORES, a/k/a

“Nino Guerrero,” the defendants, and others known and unknown, would and did, on board an

aircraft registered in the United States, manufacture, distribute, and possess with intent to distribute

a controlled substance, in violation of Title 21, United States Code, Sections 959(c) and 960(a)(3).

The controlled substance that NICOLAS MADURO MOROS, DIOSDADO

CABELLO RONDON, RAMON RODRIGUEZ CHACIN, CILIA ADELA FLORES DE

MADURO, NICOLAS ERNESTO MADURO GUERRA, a/k/a “Nicolasito,” a/k/a “The Prince,”

and HECTOR RUSTHENFORD GUERRERO FLORES, a/k/a “Nifio Guerrero,” the defendants,

conspired to (i) import into the United States and into the customs territory of the United States

from a place outside thereof, (ii) manufacture and distribute, intending, knowing, and having

reasonable cause to believe that such substance would be unlawfully imported into the United

States and into waters within a distance of 12 miles of the coast of the United States from a place

outside thereof, and (iii) manufacture, distribute, and possess on board an aircraft registered in the

United States, was five kilograms and more of mixtures and substances containing a detectable

amount of cocaine, in violation of Title 21, United States Code, Section 960(b)(l)(B).

(Title 21, United States Code, Section 963; and Title 18, United States Code, Section 3238.)

COUNT THREE (Possession of Machineguns and Destructive Devices)

The Grand Jury further charges:

Paragraphs 1 through 21 of this Superseding Indictment are realleged and

incorporated by reference as though fully set forth herein.

From at least in or about 1999, up to and including in or about 2025, in an offense

begun and committed out of the jurisdiction of any particular State or district of the United States,

and for which at least one of two or more joint offenders has been and will be first brought to and

arrested in the Southern District of New York, NICOLAS MADURO MOROS, DIOSDADO

CABELLO RONDON, RAMON RODRIGUEZ CHACIN, CILIA ADELA FLORES DE

MADURO, NICOLAS ERNESTO MADURO GUERRA, a/k/a “Nicolasito,” a/k/a “The Prince,”

and HECTOR RUSTHENFORD GUERRERO FLORES, a/k/a “Nifio Guerrero,” the defendants,

during and in relation to a drug trafficking crime for which they may be prosecuted in a court of

the United States, to wit, for MADURO MOROS, CABELLO RONDON, and RODRIGUEZ

CHACIN, the controlled substance offenses charged in Counts One and Two of this Superseding

Indictment, and for FLORES DE MADURO, MADURO GUERRA, and GUERRERO FLORES

the controlled substance offense charged in Count Two of this Superseding Indictment, knowingly

used and carried firearms, and, in furtherance of such crimes, knowingly possessed firearms, and

aided and abetted the use, carrying, and possession of firearms, to wit, machineguns that were

capable of automatically shooting more than one shot, without manual reloading, by a single

function of the trigger, as well as destructive devices.

(Title 18, United States Code, Sections 924(c)(l)(A), 924(c)(l)(B)(ii), 3238, and 2.)

COUNTFOUR (Conspiracy to Possess Machineguns and Destructive Devices)