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Yet Another Individual Enforcement Action Involving Venezuela


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.

According to the DOJ release:

“[F]rom at least 2015 through at least May 2019, Rafael Rixon Rafael Moreno Oropeza, 46, allegedly engaged in a scheme to obtained multimillion-dollar contracts from Petropiar by paying bribes to senior officials at Petropiar. Moreno allegedly agreed to pay a $1 million bribe to a senior official in the Venezuelan government to install another person as a high-ranking official in the procurement division of Petropiar. In addition, Moreno allegedly sent millions of dollars in bribe payments to senior Petropiar officials from accounts he controlled in South Florida. In exchange for these bribe payments, Moreno allegedly received benefits including over $30 million in payments on contracts from Petropiar to accounts Moreno controlled in South Florida. Illustrative of this, Moreno received approximately $2.7 million from a Petropiar contract to supply breathing devices, a contract whose price had been allegedly inflated to 100 times the actual cost. Moreno allegedly used the proceeds obtained from the Petropiar contracts for his own personal benefit, including to purchase real estate, a private jet, and luxury vehicles in South Florida.”

According to the DOJ release, “Moreno is charged with conspiracy to commit money laundering; concealment money laundering; international promotional money laundering; and engaging in transactions involving criminally derived property.”

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