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DOJ Announces Guilty Pleas By Former Unaoil Executives

By on October 31, 2019 in 2019 Enforcement Actions, Algeria, Angola, Azerbaijan, Congo, Cyrus Ahsani, DOJ Enforcement Action, Foreign Nationals, Foreign Official, Foreign Officials, Gaining Access to Confidential Documents, Iran, Iraq, Kazakhstan, Libya, Oil and Gas Industry, Saman Ahsani, Steven Hunter, Syria, Unaoil, Uncategorized
unaoil

Yesterday, 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.

Prior Foreign Corrupt Practices Act enforcement actions against Rolls-Royce and SBM Offshore (see here and here) involved, in whole or in part, Unaoil and the Ahsani information refers to approximately 25 other companies including approximately ten U.S. based issuers. Thus, it is likely that additional FCPA enforcement actions involving, in whole or in part, Unaoil will be forthcoming.

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TechnipFMC Joins FCPA Repeat Offender Club, Resolves Net $81.9 Million DOJ FCPA Enforcement Action, SEC Enforcement Action Forthcoming, Individual Criminally Charged

By on June 27, 2019 in 2019 Enforcement Actions, Brazil, DOJ Enforcement Action, Hiring Family Members of Foreign Officials, Iraq, Keppel Offshore & Marine, Oil and Gas Industry, Repeat Offenders, Technip, TechnipFMC, Unaoil, Zwi Skornicki
technipfmc

That’s a dense headline, but there was much at play in this DOJ announcement from earlier this week.

First, Technip joined the ever growing list of FCPA repeat offenders (see here) as the company previously resolved a $340 million FCPA enforcement action in 2010 concerning conduct at Bonny Island, Nigeria. (See here and here for prior posts). For good measure, as highlighted in this prior post, in 2016 FMC Technologies resolved a so-called non-FCPA, FCPA enforcement action.

Second, most FCPA enforcement actions against issuers that include a DOJ and SEC component are resolved on the same day, however this week’s development was DOJ only and this company press release states “TechnipFMC has reached an agreement in principle with the SEC Staff, subject to final SEC approval.”

Third, in connection with the same core conduct alleged in the DOJ enforcement action the DOJ also criminally charged Zwi Skornicki (a citizen of Brazil).

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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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SBM Offshore Resolves $238 Million FCPA Enforcement Action

By on November 29, 2017 in 2017 Enforcement Actions, Angola, Anything of Value, Brazil, DOJ Enforcement Action, Equitorial Guinea, Foreign Non-Issuer Company, Hiring Family Members of Foreign Officials, Iraq, Kazakhstan, Oil and Gas Industry, Paul Bond, SBM Offshore, Serious Fraud Office, Stephen Whiteley, Third Parties, Travel and Entertainment, Unaoil, United Kingdom, Voluntary Disclosure
sbm

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. In connection with this action, the company disclosed: ““the United States Department of Justice has informed SBM Offshore that it is not prosecuting the Company and has closed its inquiry into the matter.”

Fast forward to earlier this month when, as highlighted in this prior post, the DOJ announced resolution of criminal charges against former SBM Offshore executive Anthony Mace and Robert Zubiate for their roles in a scheme to bribe foreign government officials in Brazil, Angola and Equatorial Guinea.

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Friday Roundup

By on November 17, 2017 in Basil Al Jarah, Brazil, FCPA Reform, Internal Controls, ISO 37001, Jurisdiction, Kokesh, Microsoft, Monitor, Multimedia, Saman Ahsani, SBM Offshore, SEC, Serious Fraud Office, Unaoil, United Kingdom, Ziad Akle
Roundup

Quotable, SEC Annual Report, it’s called the rule of law – deal with it, across the pond, more ISO 37001 puff pieces, monitor related, for your viewing pleasure, and for the reading stack. It’s all here in the Friday roundup.

Quotable

To those still hyperventilating about Foreign Corrupt Practices Act enforcement in the Trump administration (see here and here), perhaps this might calm you down. As reported here by Wall Street Journal Risk & Compliance: “[FCPA Unit Chief Daniel Kahn dismissed the suggestion that President Donald Trump‘s previous criticism of the FCPA has had any effect on the department’s enforcement of the law. Mr. Kahn said he “spanned both administrations,” referring to Mr. Trump’s predecessor, President Barack Obama, adding, “I am continuing to do what I do.”

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