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The Case That Just Keeps On Giving – DOJ Announces Additional Charges In PDVSA Bribery Action Against Employees Of Swiss Wealth Management Firm – Previously Charged FCPA Defendant Files Motion To Dismiss

PDVSA

Several prior posts (see hereherehere and here for instance) have highlighted the clustering phenomenon and how a few discreet instances of alleged bribery yield an inordinate amount of Foreign Corrupt Practices Act enforcement activity against individuals.

One such example is the DOJ’s long-standing enforcement action (charges were first brought in late 2015) in connection with alleged corrupt schemes to secure contracts from Venezuela’s state-owned and state-controlled energy company, PDVSA.

In this recently unsealed indictment, Nervis Villalobos Cardenas (a citizen of Venezuela), Daisy Rafoi Bleuler (a citizen of Switzerland and partner in a Swiss Wealth Management firm), and Paulo Caqueiro Murta (a citizen of Portugal and Switzerland and employee in a Swiss Management firm) were charged with conspiracy to violate the FCPA’s anti-bribery provisions as well as other offenses. In the indictment, various former employees of PDVSA entities (alleged to be “foreign officials”) were also charged with money laundering offenses. As highlighted in this prior post, Villalobos was previously charged with FCPA and related offenses in early 2018.

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SEC Brings Another Enforcement Action Against A Former Cognizant Executive

Thiruvengadam

Approximately 90% of SEC corporate FCPA enforcement actions in recent years have lacked any related charges against company employees.

A bit unusual then that the February 2019 enforcement action against Cognizant Technology Solutions (see here) has resulted in not one, not two, but three individual enforcement actions as last Friday the SEC announced an administrative action against Sridhar Thiruvengadam (pictured – an Indian national and resident who previously served as Cognizant’s Chief Operating Officer).

Unlike the two prior individuals charged by the SEC and DOJ (Gordon Coburn and Steven Schwartz) who appear to be putting the government to its burden of proof, Thiruvengadam, without admitting or denying the SEC’s findings, agreed to pay a $50,000 civil penalty in an enforcement action that lacked any U.S. jurisdictional allegation other than that Thiruvengadam participated in a video conference from India with certain executives who participated in the video conference from the U.S.

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Individual Pleads Guilty To FCPA And Related Offenses In Connection With Uganda Adoption Scheme

UgandaAdoption

In a fact pattern believed to be a first in Foreign Corrupt Practices Act history, last week the DOJ announced that Robin Longoria (an individual who managed aspects of an international program at an Ohio-based adoption agency) pleaded guilty to one count of conspiring to violate the FCPA’s anti-bribery provisions and to commit wire fraud and visa fraud “for her role in a scheme to corruptly facilitate adoptions of Ugandan children through bribing Ugandan officials and defrauding U.S. adoptive parents and the U.S. Department of State.”

According to this media report, the adoption agency is now defunct European Adoption Consultants.

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DOJ Brings Additional Criminal Charges In Connection With PetroEcuador Bribery Scheme

petroecuador

Similar to how the April 2018 indictment of Frank Roberto Chatburn Ripalda alleging a bribery scheme involving PetroEcuador officials generally went unnoticed (see here for the prior post), this May 2019 indictment of Armengol Alfonso Cevallas Diaz (an Ecuadorian citizen) and Jose Melquiades Cisneros Alarcon (an Ecuadorian citizen and permanent resident of the U.S.) concerning the same alleged bribery scheme also generally went unnoticed.

The indictment charges Cevallos and Cisneros with conspiracy to violate the FCPA’s anti-bribery provisions, conspiracy to commit money laundering, and numerous money laundering offenses.

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Stiffed By Co-Conspirators, Individual Cooperates With Government And The End Result Is Yet Another FCPA Enforcement Action Concerning Conduct In Venezuela

corpoelec

Earlier this week, the DOJ announced yet another Foreign Corrupt Practices Act and related enforcement action concerning conduct in Venezuela.

Jesus Ramon Veroes and Luis Alberto Chacin Haddad were each charged and plead guilty to conspiracy to violate the FCPA’s anti-bribery provisions in connection with obtaining various contracts with Corporacion Electric Nacional S.A. (Corpoelec), Venezuela’s state-owned electric company.

In the resolution documents, Veroes is described as a Venezuelan citizen whose close relative is the President of NV Oriental Trading Corporation (a company based in Doral, Florida) and Chacin is described as a Venezuelan citizen and resident of the U.S. who owns and manages businesses in Miami including Search Trading LLC and Headline LLC (companies that purchase goods from around the world for export to Central and South America).

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