That's kind of meaningless, since the director of CITGO's US operations, Félix M. Rodriguez, reports directly to Hugo Chavez.
Here he is in the Bronx, speaking in front of a banner that reads "From the Venezuelan Heart to the U.S. Hearth."
Oh, I fully agree. However, the law may state that since there is a U.S. presence with Citgo in Houston, it may not be considered a "foreign" company or government agency, thus circumventing the limitation. Hey, I hope they nail him, but I think the lawyers would have at least covered their butts on this.