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Issues To Consider From The Frank’s Enforcement Action

Issues

This recent post highlighted the approximate $8 million FCPA enforcement action against Frank’s International based on conduct in Angola.

This post highlights additional issues to consider.

Timeline

As highlighted in this prior post, in June 2016 Frank’s International disclosed:

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Frank’s International Resolves $8 Million FCPA Enforcement Action

Frank's

The SEC has announced that Frank’s International N.V., (a Dutch oilfield services provider) now known as Expro Group Holdings N.V., has resolved an approximate $8 million Foreign Corrupt Practices Act enforcement action.

The conduct at issue based focuses on Angola and occurred between 2008 and 2014 (in other words approximately 10-15 years ago).

This administrative order finds in summary fashion:

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Friday Roundup

Roundup

Firtash extradition, scrutiny alerts and updates, spot-on observation, and refreshing words. It’s all here in the Friday roundup.

Firtash Extradition

In April 2014, the DOJ announced the unsealing of a criminal indictment charging six individuals “with participating in an alleged international racketeering conspiracy involving bribes of state and central government officials in India to allow the mining of titanium minerals.” (See here for the prior post).

Among those charged was Dmitry Firtash, a high-profile Ukrainian businessman.

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Friday Roundup

Roundup

Positive feedback, guilty plea, scrutiny alerts and updates, an instrumentality with mouse ears?, rant alert, quotable, and for the reading stack. It’s all here in the Friday roundup.

Positive Feedback

In running FCPA Professor for nearly seven years, I often feel like the captain of a ship in a wide, vast ocean. My metrics tell me people are reading, but feedback tends to be sparse. I take this as a good sign given that negative feedback is more likely to occur than positive feedback.

Thus, I appreciated much positive feedback in connection with the recent post “Denied by the DOJ.”

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