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FCPA Defendant Jeffrey Chow In His Own Words


As highlighted in this prior post, Jeffrey Chow (a U.S. citizen and Tulane educated lawyer who had various positions in the legal department of KOM) was criminally charged in connection with the Keppel Offshore & Marine Foreign Corrupt Practices Act enforcement action.

During his October 2017 plea hearing (see here for the transcript), the presiding judge gave Chow an opportunity to state, in his own words, what exactly he did in connection with the bribery scheme.

Set forth below is what Chow said.

“I worked in the Legal Department at Keppel Offshore Marine for over 25 years and among my duties and responsibilities were to draft and prepare contracts with the company’s agents and one of those was an agent in Brazil.

By no later than 2008, I realized that Keppel was overpaying the agent, sometimes by millions of dollars, so that the agent could pay bribes to individuals who could help Keppel Offshore Marine doing business with Petrobras. The Petrobras was a Brazilian state — state-owned and controlled oil company.

Although no one ever named the bribe recipients for me, I knew that they were government officials and ruling political party. I should have refused to draft the contract that we used for paying bribes and I should have resigned from Keppel. Instead, I discussed the economic terms of the contracts with my seniors at Keppel and acting in agreement with my seniors, and others at Keppel, I drafted the contracts and made sure that they were executed.

And at least one case, it was in the U.S., that I sent the executed copy of the contract from Houston, Texas to the agent to confirm that my seniors at Keppel had signed the contract.

While I didn’t negotiate the contracts or make the decisions to pay the bribes, I knew that the contracts existed to make the payments legitimate and that they were an important part of the bribery scheme.

I am deeply sorry for my conduct.”

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