Yesterday, the SEC announced this rather unusual Foreign Corrupt Practices Act enforcement action against Vantage Drilling.
What made it rather unusual is that the administrative action only found violations of the FCPA’s internal controls provisions concerning its unique relationship with a former outside director and shareholder that “created a risk that [the company] was providing or reimbursing funds that [the Director] intended to use to make improper payments to officials at Petrobras” in connection with obtaining a drilling services contract.
