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DOJ Charges Well-Known Venezuelan Billionaire Raul Gorrin With FCPA And Related Offenses

Gorrin

I recently had a conversation with a lawyer who speculated that the recent spate of Venezuela-focused Foreign Corrupt Practices Act enforcement actions was part of a U.S. government effort to facilitate regime change in the country.

Who knows, but it is hard to ignore the many recent FCPA enforcement actions focused on conduct in Venezuela (see hereherehere and here for prior posts).

The latest is this recently unsealed criminal indictment against Raul Gorrin Belisario, a well-known Venezuelan businessman and described by the DOJ as a citizen and national of Venezuela who at various time periods relevant to the charges was a resident of the U.S. with a residence in Florida.

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DOJ Quietly Dismisses Criminal Charges Against Gadio

Gadio

As highlighted in this prior post, in November 2017 the DOJ announced that Chi Ping Patrick Ho and Cheikh Gadio  were criminally charged with conspiring to violate the Foreign Corrupt Practices Act, violating the FCPA, conspiring to commit international money laundering, and committing international money laundering.

According to the DOJ: “[T]he defendants engaged in two bribery schemes to pay high-level officials of Chad and Uganda in exchange for business advantages for the Energy Company, a Shanghai-headquartered multibillion-dollar conglomerate that operates internationally in the energy and financial sectors.”

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The Case That Just Keeps On Giving – DOJ Announces Additional Charges In PDVSA Bribery Action

PDVSA

Several prior posts (see herehere 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.

Yesterday, the DOJ announced that Jose Manuel Gonzalez Testino (Gonzalez – a dual U.S.-Venezuelan citizen) was arrested at Miami International Airport based on a criminal complaint charging conspiracy to violate the FCPA and a substantive FCPA violation for “conspiring to make, and making, corrupt payments to an official [at PDVSA] in exchange for favorable business treatment with PDVSA.”

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Yet Another Civil Action Concerning Bribery And Corruption

Judicial Decision

In this post discussing a recent civil action filed by Harvest Natural Resources Inc. against various former high-ranking officials at Venezuela’s national oil company Petroleos de Venezuela, S.A. (“PDVSA”) and others, Tom Fox (who calls himself the Compliance Evangelist) asserts “bribery and corruption are rarely used as the basis of civil actions between entities and individuals.”

Not true. Bribery and corruption allegations are frequently used as the basis for civil litigation and it would be nice if commentators engaged in a bit of research before hitting the publish button and polluting the internet with false and misleading information. 

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The Case That Keeps On Giving – DOJ Announces Additional Charges In PDVSA Bribery Action

PDVSA

Several prior posts (see here 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.

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.

Yesterday, the DOJ announced that additional criminal charges were unsealed “against five former Venezuelan government officials for their alleged participation in an international money laundering scheme involving bribes made to corruptly secure energy contracts from Venezuela’s state-owned and state-controlled energy company, PDVSA.”

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