b'Enforcement ActionsAgainst IndividualsThere were FCPA charges filed against 14 individuals inthat De Jongh controlled. De Jongh is also alleged to 2020.have accepted a number of gifts from Farias-Perez and Gonzalez, including tickets to the 2014 World Series, Super Bowl XLIX, and a U2 concert. The indictment United States v. Tulio Anibal Farias-Perez,identifies De Jongha dual U.S.-Venezuelan citizenNo. 20-cr-89 (S.D. Tex.) and United States v.as a foreign official under the FCPA. Jose Luis De Jongh-Atencio, No. H-20-4:20- In exchange for the bribery payments and gifts, De CR-305 (S.D. Tex.)Jongh is alleged to have given Farias-Perez and On February 7, 2020, the DOJ announced that it hadGonzalez a number of unfair business advantages, filed a FCPA enforcement action against Tulio Anibalsuch as supply and service contracts with Citgo and Farias-Perez (Farias-Perez), a Venezuelan citizenPDVSA; confidential, non-public information about lawfully residing in Texas, arising out of the allegedPDVSAs bidding process; and priority over other money laundering conspiracy involving Petrleos devendors for payments owed under existing contracts. Venezuela S.A. (PDVSA), Venezuelas state-ownedTo disguise the nature, source, and ownership of the oil company. Farias-Perez and his business partner,illegal payments, the parties created false invoices Manuel Gonzalez Testino (Gonzalez), each held 50%for goods and services that were never provided to ownership shares in several closely-held corporationsPDVSA; transferred and received illegal payments from that obtained contracts with PDVSA. Most of thebank accounts other than those held by companies allegations involve a company owned by Gonzalez andthat had been awarded contracts with PDVSA; and Farias-Perez originally incorporated in Florida and laterasked PDVSA officials to provide information for bank in Panama and Switzerland.accounts that they had access to but that were held in the names of companies, relatives, and close friends. The DOJ alleges that from 2011 through 2018, Farias- Notably, the charges include allegations made by a Perez engaged in a money laundering conspiracyformer employee who tracked purchase orders and by paying bribes to PDVSA officials in exchange forbribe payments paid by Farias-Perez and Gonzalez. lucrative contracts for one of the companies he andThe former employee used spreadsheets to track the Gonzalez owned. The DOJ alleges that Farias-Perezbribe amounts that had been paid to PDVSA officials paid cash bribes to PDVSA officials at in-person meet- under numerous inflated contracts.ings; transferred money to bank accounts that PDVSAU.S. federal law enforcement began investigating officials or their relatives controlled; paid for teamcorruption at PDVSA in late 2017. De Jongh was dinners in Houston for the PDVSA officials that heindicted separately on July 16, 2020 for his role in had bribed; and gave PDVSA officials artwork, jewelry,the scheme. The indictment alleges that De Jongh watches, and other luxury goods. Most of the allegations involve bribes paid to Jose Luis De Jongh Atencio (De Jongh), a procurement officerIn total, twenty-seven individuals have and manager within the Special Projects Group at PVDSAs Houston-based subsidiary, Citgo Petroleumnow been charged in connection with the Corporation (Citgo). In his capacity as a procure- ongoing DOJ investigation into PDVSA, ment officer, De Jongh was responsible for obtaining goods and services for PDVSA. The DOJ claims thatindictments for which date back to Farias-Perez paid De Jongh $575,000 in 15 separateDecember 10, 2015. transfers to a Panama bank account of a shell company 24'