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.