Citgo Archives - FCPA Professor

Citgo Turns Plaintiff And Sues FCPA Violator For Bribing Its Employees

By Mike Koehler on May 28, 2020 in Citgo, Jose Manuel Gonzalez Testino, Related Civil Litigation

As highlighted in this prior post, in May 2019 Jose Manuel Gonzalez Testino pleaded guilty to, among other charges, one count of conspiracy to violate the Foreign Corrupt Practices Act and one count of violating the FCPA for providing things of value to Citgo Petroleum Corp. (a subsidiary of Petroleos de Venezuela S.A. – the Venezuelan state-owned oil company).

Recently, Citgo turned plaintiff and sued Testino and his associated company Petroleum Logistics Service Corp. (PLS) for bribing its employees.

Citgo Reportedly Under Scrutiny

By Mike Koehler on June 4, 2019 in Citgo, Venezuela

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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Citgo Reportedly Under Scrutiny

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