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As highlighted in this prior post, in connection with the May 2022 Glencore FCPA enforcement action, the majority owners of Crusader Health (Ian and Laureth Hagen) petitioned the court in the underlying enforcement action to file a restitution claim under the Mandatory Victims Restitution Act (MVRA) and the Crime Victims Act on the basis that the entity was a victim of Glencore’s conduct in the Democratic Republic of Congo. The court granted the petition.

As highlighted in this prior post, Glencore acknowledged “that Crusader—and by extension, the Hagens—was harmed by the offense to which Glencore has pled guilty, and it is prepared to pay restitution in the amount of any loss directly and proximately caused by that offense.” However, Glencore disputed the amount of restitution properly owed.

Recently, the court awarded Crusader restitution of approximately $29.7 million (an amount less than the approximate $48.4 – $50.3 million Crusader sought). See U.S. v. Glencore International 2023 WL 2242469.

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Citgo Turns Plaintiff And Sues FCPA Violator For Bribing Its Employees


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.

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