As Houston is still the epicenter of the Foreign Corrupt Practices Act enforcement world, it is probably not too surprising that the Petrobras scandal has reached the Lone Star state. This week there were two reports of Houston-based companies with ties to the corruption scandal currently engulfing Brazil at this time. The first involves the Houston-based real estate company Hines and its Brazilian operations and, the second, an oil refinery in the Houston suburb Pasadena.
To begin, we need to go back to November 2015, when the Houston Chronicle reported on a refinery just outside Houston, in Pasadena, which had become a focal point in the ongoing Petrobras bribery and corruption scandal. If the allegations are correct, it would also appear that there is clear U.S. jurisdiction for the enforcement of an FCPA violation.
