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The top attorney at Citgo Petroleum Corp. has been given the additional title of chief compliance and ethics officer, the company announced, amid a bribery investigation from the Department of Justice.

Jack Lynch, vice president of legal and government affairs and chief compliance & ethics officer at Citgo Petroleum Corp. (Courtesy photo)

Jack Lynch, who became vice president of legal and government affairs of Citgo in October, has been made the top compliance professional at the oil refinery. Lynch, who is based in Houston, will oversee the compliance department, which is staffed by 12 compliance professionals, and Citgo's compliance committee. He will periodically evaluate the effectiveness of the company's compliance and ethics program.

Lynch is not the company's first compliance leader. Rick Esser most recently served as the vice president of compliance and chief strategy officer. No one held the top compliance role at Citgo in the interim.

In his new role, Lynch reports directly to CEO Carlos Jordá and has direct reporting access to the audit committee of the board of directors.

"I've found that the tone is best delivered from the top," Lynch explained in an interview with Corporate Counsel. "The CEO and the audit committee want to hear what the state of the company's culture is. This gives me an opportunity to go to them without a screen."

Lynch's appointment comes roughly eight months after the Department of Justice subpoenaed Citgo over a bribery investigation in Venezuela. Jose Manuel Gonzalez Testino, a dual U.S.-Venezuelan citizen, was arrested in 2018 after he admitted to making bribe payments to several Petroleos de Venezuela S.A. officials who were based in Houston and employed by Citgo. Citgo had previously stated it is cooperating with authorities. The company declined to comment on the Department of Justice's ongoing investigation.

Lynch will continue to oversee the company's legal department, which he said is independent of the compliance function at Citgo. There is an efficiency to having him oversee both functions, he said, and it will help him prioritize compliance and ethics goals for the company.

Lynch wants the compliance program at Citgo to go beyond the federal sentencing guidelines of the Department of Justice's guidance memoranda.

"I'd like to make sure that throughout the company we have a working environment where reasoned and ethical decisions are being made daily," Lynch explained. "As they say here, compliance and ethics are everyone's business, every day."

The goals he hopes to achieve largely involve giving workers a feeling that they will not be reprimanded for speaking up and that their concerns will be taken seriously.

"There is a lot going on here. When employees speak up with concerns at the company, it's a culture benefit," Lynch said.

Apart from the ongoing Department of Justice probe, Citgo had previously been accused of firing a whistleblower. However, a federal judge in Illinois ruled in Arias v. CITGO Petroleum Corp. that the company presented enough evidence to show they fired Amando Arias for inappropriate behavior. In 2013, Citgo settled allegations with the Department of Justice and the U.S. Environmental Protection Agency over alleged violations of the Clean Air Act and paid a $737,000 civil fine.

Before coming to Citgo in October, Lynch spent 18 years working at British Petroleum. There, he was responsible for overseeing legal issues related to the Deepwater Horizon oil spill. He has also worked in-house at Caliber System Inc. as general counsel and as a commercial law trial partner at what is now Squire Patton Boggs. Lynch is a graduate of Case Western Reserve University School of Law.