Several prior posts (see here, 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 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.”
