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Saman Ahsani Sentenced

By on January 31, 2023 in FCPA Sentences, Saman Ahsani, Unaoil
Ahsani

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.

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Honeywell Resolves Net $82 Million FCPA Enforcement Action Concerning Conduct In Brazil And Algeria

By on December 20, 2022 in 2022 Enforcement Action, Algeria, Brazil, DOJ Enforcement Action, Honeywell, Oil and Gas Industry, SEC Enforcement Action, Third Parties, Unaoil
Honeywell

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).

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Petrofac Resolves Bribery Act Enforcement Action

By on October 5, 2021 in 2021 Enforcement Actions, Iraq, Oil and Gas Industry, Petrofac, Saudi Arabia, Serious Fraud Office, SFO, Unaoil, United Arab Emirates
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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Potpourri

By on July 29, 2020 in Basil Al Jarah, Edward Thiessen, FCPA Sentences, Och-Ziff Capital, Och-Ziff Capital Management, Restitution, Sculptor Capital Management, Serious Fraud Office, SFO, Stephen Whiteley, Unaoil, United Kingdom, Victims, Ziad Akle
Potpourri

Agreement in Principle

As highlighted in prior posts here and here in 2016 hedge fund Och-Ziff resolved a $412 million Foreign Corrupt Practices Act enforcement action concerning improper business practices in various African countries.

As highlighted in this 2018 post, former shareholders of Canadian mining company Africo Resources Ltd. (“Claimants”) sough restitution pursuant to the Mandatory Victims Restitution Act for losses allegedly incurred as a result of Och-Ziff’s bribery of corrupt officials in the Democratic Republic of the Congo.

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Unaoil – The Trace International Piece Of The Puzzle

By on November 1, 2019 in Compliance, Due Diligence, FCPA Inc., Unaoil
pieceofpuzzle

Trace International describes itself as “a globally recognized anti-bribery business organization and leading provider of third party risk management solutions.” (See here). According to Trace, its “due diligence solutions” are “based on internationally accepted best practices and our experience and familiarity with the compliance needs of multinational companies.”

According to Trace, being “Trace Certified” “means that you or your company have completed a comprehensive due diligence process administered by TRACE, the world’s leading anti-bribery standard setting organization.” Trace states that “the successful completion of TRACE certification demonstrates your commitment to commercial transparency, allowing you to serve as a valued business partner to multinational companies” and that one of the advantages of being Trace certified is “gain[ing] a valuable compliance credential that differentiates you from competitors and is widely recognized in the international business community.” (See here).

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