It is certainly one thing to fear arrest for violating criminal laws prohibiting bribery and corruption, such as the FCPA. Now the Venezuelan government has opened up a new level of fear for officers, directors, and even employees of the U.S.-based company Citgo Petroleum Co., as it has been reported that six top company officials were detained last week while at business meetings in Venezuela. Although a Houston-TX based company, Citgo Petroleum is a subsidiary of the Venezuelan state-owned oil company Petróleos de Venezuela SA (PdVSA). Those detained were the acting president of the company and five members of the company’s board. Their alleged crime was offering bonds to finance the company’s continued operations.

Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in...