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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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Citgo Reportedly Under Scrutiny

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This 2009 post highlighted, in connection with a Foreign Corrupt Practices Act enforcement action concerning conduct involving Petroleos de Venezuela S.A. (PDVSA) (the Venezuelan state-owned oil company) that one of PDVSA’s wholly-owned subsidiaries is Citgo Petroleum Corp.

It was noted that, under the DOJ/SEC’s interpretation, all CITGO employees are thus “foreign officials” under the FCPA despite the fact that CITGO is a Delaware corporation based in Houston. It was further noted that Citgo is both subject to the FCPA and all of its employees (under the DOJ/SEC interpretation) are “foreign officials” under the FCPA.

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

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.

Yesterday, the DOJ announced that two additional individuals were criminally charged “for their alleged roles in a scheme to corruptly secure business advantages, including contracts and payment on past due invoices, from Venezuela’s state-owned and state-controlled energy company, Petroleos de Venezuela S.A. (PDVSA).”

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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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