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Venezuelan Citizen Charged With FCPA Offenses In Connection Venezuelan Food Bribery Scheme

By on September 14, 2023 in 2023 Enforcement Action, Alvaro Pulido Vargas, Ana Guillermo Luis, Carlos Rolando Lizcano Manrique, DOJ Enforcement Action, Emmanuel Enrique Rubio Gonzalez, Foreign Nationals, Jose Gregorio Vielma-Mora, Jurisdiction, Venezuela
CLAP

Earlier this week a criminal information was filed in the Southern District of Florida charging Orlando Alfonso Contreras Saab (a citizen of Venezuela) with conspiracy to violate the FCPA in connection with an alleged Venezuelan bribery scheme.

According to the information, Contreras Saab and his co-conspirators “unlawfully enrich[ed] themselves by engaging in a scheme to bribe Venezuelan officials to obtain and retain contracts and other business advantages, including obtaining mutli-million-dollar contracts with entities and instrumentalities owned and controlled by the Venezuelan government for the production, importation, and distribution of food and medicine to the people of Venezuela.”

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Potpourri

By on February 7, 2023 in FCPA Related Charges, Keppel Offshore & Marine, Venezuela
Potpourri

Judicial Bribery

As highlighted in this article:

“A Venezuelan Supreme Court justice and former president of that court [Maikel Jose Moreno Perez] has been indicted in Florida on charges he accepted bribes totaling around $10 million in exchange for leniency or case dismissals, spending the money on luxury homes and vacations abroad.”

According to the indictment, the bribes were intended to influence the justice to resolve cases in a manner favorable to Venezuelan contractors who owned companies that received funds from Venezuelan government-controlled entities. Certain of the bribe payments were used to purchase real estate in the U.S. and/or passed through U.S. bank accounts.

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Yet Another Individual Enforcement Action Involving Venezuela

By on August 25, 2022 in 2022 Enforcement Action, DOJ Enforcement Action, Individual Enforcement Action, Venezuela
Venez

As highlighted in this recent post, approximately 55% of individual enforcement actions on the DOJ’s FCPA website since 2018 concern non-FCPA offenses in connection with alleged foreign bribery schemes – most often money laundering offenses – and an astounding 37% or so of individual enforcement actions involve just one country: Venezuela.

Continuing this theme, the DOJ announced yesterday that a federal grand jury in Miami returned an indictment charging Rafael Rixon Rafael Moreno Oropeza (a Venezuelan national) for laundering the proceeds of substantially inflated procurement contracts obtained by making bribe payments to senior officials at Petropiar, a joint venture between Venezuela’s state-owned and state-controlled energy company and an American oil company.

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Time Spent On The DOJ’s FCPA Website

By on August 8, 2022 in DOJ, Ecuador, FCPA Statistics, Individual Enforcement Action, Venezuela
lookatscreen

I recently spent some time on the DOJ’s FCPA Website and looked at all “Enforcement Actions” involving individuals from 2018 to the present.

Many of the separately listed “Enforcement Actions” involve multiple individual defendants and some individual enforcement actions are listed in more than one year.

By my estimation though, the DOJ’s FCPA website – from 2018 to the present – contains information about 175 individuals and set forth below are some interesting statistics.

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Glencore Resolves An Approximately $443 Million Net FCPA Enforcement Action

By on May 25, 2022 in 2022 Enforcement Action, Brazil, Cameroon, Congo, DOJ Enforcement Action, Equatorial Guinea, Foreign Non-Issuer Company, Glencore, Ivory Coast, Monitor, Nigeria, Oil and Gas Industry, Permits / Licenses / Customs / Tax, Third Parties, Venezuela
glencore

In mid-2018 Glencore (a commodities company incorporated in the United Kingdom and headquartered in Switzerland disclosed that it was under scrutiny by the DOJ. (See here for the prior post).

Specifically, the company disclosed:

“Glencore Ltd, a subsidiary of Glencore plc, has received a subpoena dated 2 July, 2018 from the US Department of Justice to produce documents and other records with respect to compliance with the Foreign Corrupt Practices Act and United States money laundering statutes.  The requested documents relate to the Glencore Group’s business in Nigeria, the Democratic Republic of Congo and Venezuela from 2007 to present. Glencore is reviewing the subpoena and will provide further information in due course as appropriate.”

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