As highlighted in this prior post, in 2014 Netherlands-based SBM Offshore resolved a $240 million Dutch law enforcement action alleging improper payments to sales agents and foreign government officials in Equatorial Guinea, Angola and Brazil between 2007 through 2011.
As highlighted in this prior post, in 2017 SBM Offshore and its wholly owned U.S. subsidiary, SBM Offshore USA Inc. resolved a $238 million FCPA enforcement action concerning conduct in Brazil, Angola, Equatorial Guinea, Kazakhstan and Iraq.
As highlighted in this prior post, in 2018 SBM Offshore announced a leniency agreement with Brazil law enforcement authorities pursuant to which it agreed to pay over $300 million for conduct occurring in the country.
Earlier this week, SBM Offshore disclosed: