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Bribes As “Breakfast” And “Breakfast Servings”

breakfast

Earlier this week the DOJ announced that “Glenn Oztemel (who worked as a senior oil and gas trader at two Connecticut-based trading companies (Trading Company #1 and Trading Company #2) and Eduardo Innecco (a dual Brazilian and Italian citizen who worked as an oil and gas broker and agent for Trading Company #1 and Trading Company #2 in Brazil) were charged with FCPA and related offenses for an alleged Brazil bribery scheme.

As highlighted here, Oztemel was previously employed by Freepoint Commodities LLC.

In summary fashion, the indictment alleges:

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Honeywell Resolves Net $82 Million FCPA Enforcement Action Concerning Conduct In Brazil And Algeria

Honeywell

Turns out, things were not so well at Honeywell.

As highlighted in this prior post, in mid-2019 Honeywell disclosed that it was cooperating with the DOJ/SEC and Brazilian law enforcement investigations relating to its use of third parties in relation to Petrobras (Brazil) business as well as a matter involving a foreign subsidiary’s prior engagement of Unaoil in Algeria.

Yesterday, the DOJ and SEC announced (see here and here) a parallel Foreign Corrupt Practices Act enforcement action against Honeywell UOP (a U.S. based subsidiary of Honeywell International) and Honeywell International.

The net $82 million enforcement action involved a DOJ component (net $39.6 million) and an SEC component (net $42.4 million).

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The FCPA Repeat Offender Club Welcomes Tenaris

welcome

In 2011, Tenaris S.A. (a company headquartered in Luxembourg with American Depository Receipts listed on the New York Stock Exchange) resolved an approximate $9 million Foreign Corrupt Practices Act enforcement action regarding conduct in Uzbekistan (see here for the prior post).

For several years, Tenaris has been under scrutiny for its relationship with Petrobras in Brazil and in October 2016 the company “voluntarily notified” the SEC and DOJ. (See here).

Yesterday, the FCPA Repeat Offender Club welcomed Tenaris to its growing membership as the SEC announced an approximate $78.1 million enforcement action against the company.

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Glencore Resolves An Approximately $443 Million Net FCPA Enforcement Action

glencore

In mid-2018 Glencore (a commodities company incorporated in the United Kingdom and headquartered in Switzerland disclosed that it was under scrutiny by the DOJ. (See here for the prior post).

Specifically, the company disclosed:

“Glencore Ltd, a subsidiary of Glencore plc, has received a subpoena dated 2 July, 2018 from the US Department of Justice to produce documents and other records with respect to compliance with the Foreign Corrupt Practices Act and United States money laundering statutes.  The requested documents relate to the Glencore Group’s business in Nigeria, the Democratic Republic of Congo and Venezuela from 2007 to present. Glencore is reviewing the subpoena and will provide further information in due course as appropriate.”

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Petrofac Resolves Bribery Act Enforcement Action

Petrofac

Petrofac (a U.K. based oil and gas company with ADRs registered with the SEC) has been under scrutiny since 2016 regarding its relationship with Unaoil. (See here for the prior post).

In 2019, the U.K. Serious Fraud Office announced that David Lufkin (the former Global Head of Sales for Petrofac International Ltd.) pleaded guilty to eleven counts of bribery related to “the making of corrupt offers to influence the award of contracts to Petrofac worth in excess of USD $730 million in Iraq and in excess of USD $3.5 billion in Saudi Arabia.” (See here).

Recently, the SFO announced that it has “secured the conviction of Petrofac Limited for seven separate counts of failure to prevent bribery between 2011 and 2017.”

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