Years Later, FCPA Defendants Still Await Sentencing
As highlighted in this prior post, in October 2019, the DOJ announced that Cyrus Ahsani and Saman Ahsani (the former CEO and Chief Operations Officer of Monaco-based Unaoil) pleaded guilty in March 2019 to one count of conspiracy to violate the FCPA for their roles in a scheme to corruptly facilitate millions of dollars in bribe payments to officials in multiple countries.
The DOJ also announced that Steven Hunter (a former business development manager at Unaoil) pleaded guilty in August 2018 to one count of conspiracy to violate the FCPA.
As noted in the DOJ’s release, the Ahsanis were scheduled to be sentenced in April 2020 and Hunter was scheduled to be sentenced in March 2020.
Years Later, Certain Unaoil Executives Still Have Not Been Sentenced
As highlighted in this prior post, in October 2019, the DOJ announced that Cyrus Ahsani and Saman Ahsani (the former CEO and Chief Operations Officer of Monaco-based Unaoil) pleaded guilty in March 2019 to one count of conspiracy to violate the FCPA for their roles in a scheme to corruptly facilitate millions of dollars in bribe payments to officials in multiple countries.
The DOJ also announced that Steven Hunter (a former business development manager at Unaoil) pleaded guilty in August 2018 to one count of conspiracy to violate the FCPA.
As noted in the DOJ’s release, the Ahsanis were scheduled to be sentenced in April 2020 and Hunter was scheduled to be sentenced in March 2020.
Saman Ahsani Sentenced
As highlighted in this prior post, in October 2019, the DOJ announced that Cyrus Ahsani and Saman Ahsani (the former CEO and Chief Operations Officer of Monaco-based Unaoil) pleaded guilty in March 2019 to one count of conspiracy to violate the FCPA for their roles in a scheme to corruptly facilitate millions of dollars in bribe payments to officials in multiple countries.
The DOJ also announced that Steven Hunter (a former business development manager at Unaoil) pleaded guilty in August 2018 to one count of conspiracy to violate the FCPA.
As noted in the DOJ’s release, the Ahsanis were scheduled to be sentenced in April 2020 and Hunter was scheduled to be sentenced in March 2020.
However, this August 2022 post highlighted how the defendants still had yet to sentenced and wondered when sentencing would occur.
Honeywell Resolves Net $82 Million FCPA Enforcement Action Concerning Conduct In Brazil And Algeria
Turns out, things were not so well at Honeywell.
As highlighted in this prior post, in mid-2019 Honeywell disclosed that it was cooperating with the DOJ/SEC and Brazilian law enforcement investigations relating to its use of third parties in relation to Petrobras (Brazil) business as well as a matter involving a foreign subsidiary’s prior engagement of Unaoil in Algeria.
Yesterday, the DOJ and SEC announced (see here and here) a parallel Foreign Corrupt Practices Act enforcement action against Honeywell UOP (a U.S. based subsidiary of Honeywell International) and Honeywell International.
The net $82 million enforcement action involved a DOJ component (net $39.6 million) and an SEC component (net $42.4 million).
Petrofac Resolves Bribery Act Enforcement Action
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.”