Saudi Arabia Archives - FCPA Professor

Petrofac Resolves Bribery Act Enforcement Action

By Mike Koehler on October 5, 2021 in 2021 Enforcement Actions, Iraq, Oil and Gas Industry, Petrofac, Saudi Arabia, Serious Fraud Office, SFO, Unaoil, United Arab Emirates

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.”

Deutsche Bank Joins The Repeat Offender Club By Resolving Second FCPA Enforcement In Just 16 Months

By Mike Koehler on January 11, 2021 in 2021 Enforcement Actions, Abu Dhabi, China, Deutsche Bank, Financial Services Industry, Foreign Issuers, Internal Controls, Italy, Repeat Offenders, Saudi Arabia, Third Parties, Unsuccessful Bribery Schemes

In August 2019, Deutsche Bank paid $16.2 million “to settle changes that it violated the FCPA by hiring relatives of foreign government officials [in both the Asia Pacific Region and Russia] in order to improperly influence them in connection with investment banking business).” (See here and here for prior posts).

Late Friday, Deutsche Bank (a German investment bank and financial services company with shares traded on the NYSE between 2009 and 2016) joined the ever expanding list of FCPA repeat offenders as the DOJ and SEC announced (here and here) an approximate $122.6 million Foreign Corrupt Practices Act enforcement action focused on the company’s relationship with third parties in Abu Dhabi, Saudi Arabia, Italy, and China.

The approximate 16 month gap between Deutsche Bank’s FCPA enforcement actions is the shortest among the large group of FCPA repeat offenders.

An Accounting Fraud Matter With Some FCPA Sprinkled In

By Mike Koehler on April 7, 2020 in 2001 Enforcement Actions, American Bank Note Holographics, Financial Services Industry, Joshua Cantor, Saudi Arabia

[This post is part of a periodic series regarding “old” FCPA enforcement actions]

Foreign Corrupt Practice Act issues can be the tip of the iceberg with a company and its executives also engaging in other improper conduct. Such was the case in an enforcement action American Bank Note Holographics and its executive Joshua Cantor.

This 2001 criminal information against Joshua Cantor (during the relevant time period President or Executive Vice President and General Manager of American Bank Note Holographics, Inc. (ABNH), a subsidiary of American Banknote Corporation) is primarily a securities / accounting fraud matter.

However, Cantor was also charged with count of conspiracy to violate the FCPA’s anti-bribery provisions.

A Look At The French Enforcement Action Against Airbus

By Mike Koehler on February 18, 2020 in Airbus, Charitable Contributions, China, Colombia, Doing Business With “Foreign Officials”, Due Diligence, France, Gaining Access to Confidential Documents, Nepal, Russia, Saudi Arabia, South Korea, Third Parties

Previous posts here and here looked at the U.S. Foreign Corrupt Practices Act enforcement action against Airbus.

This previous post looked at the U.K. Bribery Act enforcement action against Airbus.

This post completes the enforcement trilogy, bylooking at the French enforcement action against Airbus.

Like the prior U.S. and U.K. bribery enforcement action, the French enforcement action against Airbus (see here for the Judicial Public Interest Agreement) focused on the use of business partners in connection with sales or attempted sales in various countries.

Microsoft Resolves Long-Standing FCPA Scrutiny By Agreeing To Pay $25.3 Million

By Mike Koehler on July 23, 2019 in 2019 Enforcement Actions, DOJ Enforcement Action, Hungary, Margins, Microsoft, Saudi Arabia, SEC Enforcement Action, Technology Industry, Thailand, Turkey

Microsoft has been under Foreign Corrupt Practices Act scrutiny since early 2013 (see here for the prior post). Yesterday, the DOJ and SEC announced here and here an aggregate $25.3 million enforcement action against the company and a Hungarian subsidiary concerning conduct in Hungary, Saudi Arabia, Thailand and Turkey.

The enforcement action involved a DOJ component involving a non-prosecution agreement involving MS Hungary in which the entity agreed to pay a $8.8 million criminal penalty and an SEC administrative order against Microsoft finding violations of the FCPA’s books and records and internal controls provisions in which the company agreed, without admitting or denying the SEC’s findings, to pay disgorgement and prejudgment interest of approximately $16.5 million.

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Petrofac Resolves Bribery Act Enforcement Action

Deutsche Bank Joins The Repeat Offender Club By Resolving Second FCPA Enforcement In Just 16 Months

An Accounting Fraud Matter With Some FCPA Sprinkled In

A Look At The French Enforcement Action Against Airbus

Microsoft Resolves Long-Standing FCPA Scrutiny By Agreeing To Pay $25.3 Million

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