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Issues To Consider From The Tysers And H.W. Wood Enforcement Actions

Issues

This previous post discussed the related DOJ Foreign Corrupt Practices Act enforcement actions against United Kingdom reinsurance brokers Tysers Insurance Brokers Limited (acquired by AUB Group in 2022) and H.W. Wood Limited for “participation in a corrupt scheme to pay bribes to Ecuadorian government officials.”

This post highlights additional issues to consider.

Timeline

AUB previously disclosed in 2022.

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U.K. Serious Fraud Office Drops Two Long-Standing Bribery Investigations

SFO2

The general equivalent to the Department of Justice in the United Kingdom is the Serious Fraud Office (SFO).

Compared to the DOJ, the SFO does a much better job of keeping the public informed of its investigations.

Recently, the SFO updated its case archive concerning two long-standing bribery investigations involving ENRC Ltd. and Rio Tinto.

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Glencore Pleads Guilty In The U.K.

glencore

In connection with the May Foreign Corrupt Practices Act enforcement action against Glencore, the U.K. Serious Fraud Office also announced that a Glencore entity was charged with seven counts of bribery in connection with its oil operations.

Yesterday, the SFO announced that:

“Glencore Energy (UK) Ltd has … been convicted on all charges of bribery brought against it by the Serious Fraud Office (SFO).  At Southwark Crown Court, the company admitted to multiple counts of paying bribes to secure access to oil and generate illicit profit. The SFO’s investigation exposed that Glencore, via its employees and agents, paid bribes of over $28 million for preferential access to oil, including increased cargoes, valuable grades of oil and preferable dates of delivery.  These actions were approved by the company across its oil operations in Nigeria, Cameroon, Ivory Coast, Equatorial Guinea and South Sudan. Glencore will be sentenced on 2nd  and 3rd November his year.”

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DOJ Quietly Releases “Declination With Disgorgement” Letter Involving JLT

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This March 15th post discussed a future $29 million “declination with disgorgement” enforcement action disclosed by Marsh & McLennan Companies, Inc. in connection with its 2019 acquisition of Jardine Lloyd Thompson Group plc (JLT).

On March 22nd, the DOJ quietly updated its FCPA Corporate Enforcement Policy declinations page by posting the March 18th “declination with disgorgement” letter.

The last time the DOJ self-identified an FCPA enforcement action as a “declination” was approximately 1.5 years ago (in August 2020).

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Petrofac Resolves Bribery Act Enforcement Action

Petrofac

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.”

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