This prior post highlighted the DOJ’s recent net $37.5 million Foreign Corrupt Practices Act enforcement action against Samsung Heavy Industries (a South Korea-based company with a branch office in Houston) focused on its relationship with Pride International (now part of Valaris plc) through which it sold a drillship to Petrobras.
This post highlights additional issues to consider from the enforcement action.
What About Pride?
The primary beneficiary, it would seem, of the conduct alleged in the SHI enforcement action is the “Chartering Company” described by the DOJ as an “offshore oil drilling company headquartered in Houston, Texas which provided contract drilling and related services to oil and gas companies.”