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This Is Not How OECD Convention Article 4 Should Work

By on December 2, 2020 in OECD, SBM Offshore
not

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:

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Mace And Zubiate Sentenced

By on September 29, 2018 in Anthony Mace, FCPA Sentences, Robert Zubiate, SBM Offshore
Prison

This previous post highlighted the DOJ’s enforcement action against Anthony Mace (the former CEO of SBM Offshore) and Robert Zubiate (a former sales and marketing executive at a company subsidiary). As highlighted in this prior post, the Mace enforcement action, in particular, should be required reading for all corporate executives.

Yesterday, the DOJ recently announced that Mace was sentenced to serve 36 months in prison and a fine of $150,000 and Zubiate was sentenced to serve 30 months in prison and a fine of $50,000. All of the sentencing documents on the court’s docket were filed under seal.

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Friday Roundup

By on August 3, 2018 in AstraZeneca, Disgorgement, Hiring Family Members of Foreign Officials, SBM Offshore, Statute of Limitations, Wal-Mart
Roundup

Impasse, quotable, scrutiny alerts, um excuse me but, and for the reading stack. It’s all here in the Friday roundup.

Impasse

Walmart’s FCPA scrutiny began in late 2011. Yet, nearly seven years later there still has not been an enforcement action.

Bloomberg reports: “Walmart Inc. set aside nearly $300 million last fall for a possible resolution with the U.S. government over international bribery allegations, a sign that an end to the years-long investigation was imminent. But eight months later, the sides are deadlocked, three people familiar with the matter said. It’s not about the money: One source of tension is prosecutors’ insistence that Walmart, the world’s largest retailer, admit to certain misconduct as part of any deal, one of the people said.”

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Friday Roundup

By on June 29, 2018 in Egbert Yvan Ferdinand Koolman, FCPA Sentences, Lawrence Parker, Leighton Holdings, McKinsey & Co., SBM Offshore, Serious Fraud Office, Unaoil, United Kingdom
Roundup

Across the pond, sentenced, unremarkable, and nonsense. It’s all here in the Friday roundup.

Across the Pond

As highlighted in this prior post, in July 2016 the U.K. Serious Fraud Office announced:

“The SFO is conducting a criminal investigation into the activities of Unaoil, its officers, its employees and its agents in connection with suspected offences of bribery, corruption and money laundering.”

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Once Again, The DOJ Shoots Itself In The Foot

By on December 11, 2017 in DOJ FCPA Corporate Enforcement Policy, SBM Offshore, Uncategorized, Voluntary Disclosure
shootingselffoot

The Department of Justice has long wanted companies to voluntarily disclose conduct that implicates the Foreign Corrupt Practices Act. The latest attempt to achieve this policy goal of course was the DOJ’s November 29th announcement of a new “FCPA Corporate Enforcement Policy.” (This post rounds up all previous posts on this topic).

Why then, literally a few hours after announcing its latest attempt to motivate companies to voluntarily disclose, did the DOJ in announcing the SBM Offshore enforcement action (see here and here for prior posts) once again (see here and here for prior similar posts) shot itself in the foot by making decisions that should result in any board member, audit committee member, or general counsel informed of current events not making the decision to voluntarily disclose?

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