Nigerian “Foreign Official” Convicted Of Various Criminal Offenses In Connection With Bribery Scheme

This previous post highlighted a DOJ criminal enforcement action against Paulinus Iheanacho Okoronkwo (also known as Pollie – a dual citizen of the U.S. and Nigeria who resides in California).

Pollie was an attorney admitted to the State Bar of California and the “sole proprietor of the Law Office of Pollie Okoronkwo where he practiced immigration law and personal injury matters, such as slip-and-fall and motor vehicle injury cases.”)

The indictment alleged that Okoronkwo was also a “foreign official serving as the general manager of the NNPC’s [Nigerian National Petroleum Corporation] Upstream Division” and further alleged the following relevant background.

U.S. Government Reportedly Investigating Chinese Government For Bribery In Nigeria

Regarding the above headline, technically, as noted in this Bloomberg report, the DOJ and SEC are investigating China Petroleum & Chemical Corporation (Sinopec – a Chinese state-owned entity) with shares traded on a U.S. exchange for bribery in Nigeria.

However, given that the DOJ and SEC consider certain state-owned entities like Sinopec to be “instrumentalities” of a foreign government, the above headline is accurate.

This previous post highlighted how there has never been an FCPA enforcement against a Chinese-based issuer, but this is likely just a matter of time as the previous post noted that Sinovac Biotech [a Beijing based company with shares traded on NASDAQ] is currently under FCPA scrutiny.

Add Sinopec to the list.