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.
‘Enforcement 40’ for 2020
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