b'received a total of $2.5 million in bribery proceeds fromPetrocedeos general counsel, head manager for businessmen including Farias-Perez and Gonzalez, theall PDVSA operations in the Orinoco region, and majority of which were used to purchase real property.general counsel of PDVSA. In 2012, Orsoni joined the For example, illicit proceeds received by De Jonghcommittee that reviewed and approved all contracts included a one-time payment from Gonzalez of overawarded by Petrocedeo. The DOJ asserts that Orsoni $1.3 million used to complete the purchase of six unitswas a foreign official under the FCPA. of commercial property in Texas. Federal law enforcement began investigating corrup-The DOJ identifies both Gonzalez and Farias-Perez astion at the PDVSA subsidiaries in late 2017. The DOJ domestic concerns as those terms are used in thealleges that, from 2012 through 2016, Orsoni partic-FCPA. In total, twenty-seven individuals have now beenipated in a conspiracy to commit money laundering charged in connection with the ongoing DOJ investi- to conceal bribe payments he received from U.S.-gation into PDVSA, indictments for which date back tobased contractors to obtain an advantage in securing December 10, 2015.procurement contracts with PDVSA and the PDVSA Farias-Perez pleaded guilty on February 19, 2020. HeSubsidiaries. The DOJ alleges that senior PDVSA offi-is facing up to 5 years in prison, 3 years of supervisedcials instructed Orsoni to ensure that certain U.S.-based release, a $250,000 fine, and restitution. He will becontractors were awarded Petrocedeo contracts, sentenced in February 2021. Gonzalez, who wasbecause the senior PDVSA officials would receive kick-charged separately in July 2018, pleaded guilty onbacks from said contractors; that Orsoni agreed to help May 29, 2019. Gonzalez sentence will be set in earlythese contractors secure contracts with Petrocedeo 2021. De Jongh has not yet entered a plea and hisand another PDVSA subsidiary in exchange for bribe case remains pending in the U.S. District Court for thepayments to Orsoni; that Orsoni concealed the nature, Southern District of Texas. source, and ownership of the bribes by arranging for the payments to flow through accounts that Orsoni controlled but that were not in his name; and that United States v. Edoardo Orsoni, No. 19-cr- Orsoni and a co-conspirator used the bribe proceeds 20725 (S.D. Fla.) and United States v. Lennysfor their own benefit. Specifically, the DOJ alleges that Rangel, No. 19-cr-20726 (S.D. Fla.)Orsoni caused contractors to wire him approximately $750,000 to a bank account in Portugal and approx-On March 11 and March 12, 2020, the DOJ announcedimately $200,000 to a Caribbean bank account. The that it had filed two related FCPA enforcement actionsDOJ also alleges that Orsoni arranged for two Miami on November 4, 2019 arising out of the allegedproperties to be purchased with the bribe payments money laundering conspiracy involving Petrleos dehe received. The DOJ seeks forfeiture of at least $4.5 Venezuela S.A. (PDVSA), Venezuelas state-ownedmillion and the two Miami properties. oil company. The DOJ alleged that PDVSA, the fourThe DOJ also brought a related enforcement action joint ventures with foreign oil companies that PDVSAagainst Lennys Rangel, a Venezuelan citizen who was controlled (the PDVSA Subsidiaries), and Petrocedeoformerly the head of procurement at Petrocedeo. The S.A. (Petrocedeo), one of the PDVSA SubsidiariesDOJ asserts that Rangel was a foreign official under that awarded hundreds of millions of dollars of procure- the FCPA. ment contracts per year, were instrumentalities of theThe DOJ alleges that between March 2015 and late Venezuelan government under the FCPA.2017, Rangel participated in a conspiracy to commit Edoardo Orsoni held several high-ranking positionsmoney laundering. As with Orsoni, the DOJ alleges at PDVSA and the PDVSA Subsidiaries, includingthat the purpose of the money laundering conspiracy 25'