In Houston last week, yet another member of Venezuelan state-run oil company PDVSA’s cabal that was engaged in systemic bribery and corruption was brought to justice. This time it was Cesar Rincon, brother of another felon who had previously pleaded guilty, Roberto Rincon. According to his unsealed indictment, Cesar Rincon admitted that he accepted bribes from his brother and others in exchange for taking official acts in his capacity as general manager of PDVSA’s procurement subsidiary.

Cesar Rincon was a part of a group named the PDVSA “management team,” which approached certain corrupt suppliers to the Venezuelan energy concern and offered to facilitate contract procurement, provide insider information and navigate the byzantine PDVSA payment process for corrupt payments. The monies paid by Roberto Rincon and others were laundered into Swiss bank accounts. In his indictment, Cesar Rincon signed an order of forfeiture for more than $7 million in ill-gotten gains to be paid back to the court. 

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...