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Next Up … Trafigura

Trafigura

First it was Sargeant Marine in 2020 (see here for the prior post).

Then it was Vitol in 2020 (see here for the prior post).

Then it was Glencore in 2022 (see here for the prior post).

Then it was Freepoint Commodities in 2023 (see here for the prior post).

Then it was Gunvor in 2024 (see here for the prior post).

Next up in the list of commodities trading (or related) companies to resolve an FCPA enforcement action is Trafigura (a company which has been under FCPA and related scrutiny for years). After accounting for various credits for related foreign law enforcement actions, the net FCPA settlement amount is approximately $100.2 million (a criminal fine amount of $53.66 million and a forfeiture amount of $46.51 million).

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Gunvor Resolves Net $474.4 Million FCPA Enforcement Action

gunvor

In 2021, Raymond Kohut (a Canadian citizen who lived in the Bahamas and worked in business development for Gunvor Group Ltd., a Switzerland based commodities firm) pleaded guilty in connection with an Ecuador bribery scheme. (See here for the prior post).

Last week, the DOJ returned to the same core conduct in announcing a Foreign Corrupt Practices Act enforcement action against Gunvor.

The net FCPA settlement amount was $474.4 million (a $187.3 million criminal fine and a $287.1 million forfeiture amount).

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Freepoint Commodities Resolves FCPA Enforcement Action

freepoint

In February 2023, the DOJ announced that Glenn Oztemel (previously employed by Freepoint Commodities LLC) and Eduardo Innecco (an agent for the company) were charged with FCPA and related offenses for an alleged Brazil bribery scheme. (See here for the prior post).

In summary fashion, the indictment alleged:

“Between in or about 2010 and continuing until in or about 2018, Glenn Oztemel and Eduardo Innecco, together and with others, agreed to pay, and did pay, bribes to foreign officials at Brazil’s state-owned and state-controlled oil and gas company, Petroleo Brasileiro S.A. – Petro bras (“Petrobras”), on behalf of Trading Company #1 and Trading Company #2. In exchange for the bribes, foreign officials at Petrobras, including Rodrigo Berkowitz (“Berkowitz”), who has been charged separately, provided Oztemel, Innecco and others with confidential information related to Petrobras’s business. The inside information and other improper assistance Berkowitz provided to Oztemel, Innecco and others gave Trading Company #1 and Trading Company #2 improper business advantages in trades with Petrobras.

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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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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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