January 24, 2018

Global Anti-Corruption Insights: Winter 2018

Update on Recent Enforcement, Litigation, and Compliance Developments

Despite a brief lull in the first few months of the Trump Administration, 2017 turned out to be yet another active year of enforcement under the US Foreign Corrupt Practices Act. The US Department of Justice brought over two dozen criminal FCPA enforcement actions against companies and individuals in 2017. In the second half of 2017, the DOJ announced three blockbuster corporate settlements in coordination with enforcement authorities in other countries—Telia agreed to pay a total of $965 million to the United States, the Netherlands, and Sweden; Keppel Offshore agreed to pay more than $422 million to the United States, Singapore, and Brazil; and SBM Offshore agreed to pay $238 million to the United States on top of the $240 million it previously paid Dutch authorities and additional penalties it is likely to pay Brazil.

The new administration appears to be doubling down on some of the policies and practices embraced during the Obama Administration. In November, the DOJ unveiled a formal FCPA Corporate Enforcement Program designed to encourage self-reporting of potential violations, cooperation with government investigations, and remediation of compliance issues. The DOJ also continued its commitment to holding individuals accountable for violations of the FCPA and other corruption laws, securing individual guilty pleas and convictions in multiple cases.

On the civil side, the US Securities and Exchange Commission resolved a range of FCPA charges in 2017, including, most recently, a multi-million dollar corporate settlement announced in September. The SEC's FCPA enforcement efforts suffered a setback in June, however, when the US Supreme Court removed a weapon from the SEC's arsenal, ruling that actions for disgorgement are subject to a five-year statute of limitations. As a result, the SEC likely will intensify its efforts to bring FCPA cases more quickly.

All signs suggest that anti-corruption enforcement and related litigation will continue apace in 2018. The first few days of the new year saw a nephew of the former head of the United Nations plead guilty to FCPA charges in connection with an international real estate deal; a Maryland businessman charged with FCPA violations and other crimes for his alleged role in bribing Russian atomic energy officials; and Brazilian state-owned oil giant Petrobras agreeing to pay nearly $3 billion to settle securities class-action litigation stemming from its international corruption scandal.

This issue of our Global Anti-Corruption Insights focuses on developments from the second half of 2017. For further information on anti-corruption developments from the first half of 2017, see Arnold & Porter Kaye Scholer LLP, Global Anti-Corruption Insights: Summer 2017.1


Key Developments in the United States

I. FCPA Enforcement Actions Against Companies »»

II. FCPA Enforcement Actions Against Individuals »»

III. Other FCPA Investigation and Enforcement News »»

IV. Corruption-Related Legal Documents »»

Global Anti-Corruption Update

I. UK SFO Charges Four in Connection with Unaoil Probe »»

II. Three F.H. Bertling Employees Fined but Avoid Prison in UK for Angolan Bribery »»

III. Swedish Court Finds Bombardier Employee Not Guilty of Bribery in Azerbaijan Railway Project »»

IV. Shell, Eni, and 15 Executives to Face Trial in Italy in $1 Billion Nigerian Bribery Case »»


I. FCPA Enforcement Actions Against Companies

Keppel Offshore Enters $422 Million Global Settlement with US, Brazilian, and Singaporean Authorities

On December 22, 2017, the DOJ announced that Singapore-based Keppel Offshore & Marine Ltd. (Keppel Offshore) entered into a deferred prosecution agreement (DPA), and its wholly owned US subsidiary pleaded guilty to conspiracy to violate the FCPA, in connection with a long-running scheme to bribe Brazilian officials. In related proceedings, Keppel Offshore settled with Brazilian and Singaporean prosecutors. The global settlement requires Keppel Offshore and its US subsidiary to pay a combined penalty of more than $422 million, with 50% going to Brazil, 25% to Singapore, and 25% to the United States. According to the DOJ, Keppel Offshore's cooperation and remediation resulted in a 25% reduction off the bottom of the applicable US Sentencing Guidelines fine range.2

Keppel Offshore admitted that from at least 2001 through at least 2014 it paid approximately $55 million in bribes to officials at Brazilian state-owned oil company Petrobras and to a governing political party in Brazil. The bribes—which were paid through inflated commissions to an intermediary, under the guise of consulting agreements—resulted in profits of over $350 million from 13 contracts with Petrobras and another Brazilian entity.3

In addition to the corporate enforcement actions, on August 29, 2017, a former member of Keppel Offshore's legal department pleaded guilty in US District Court for the Eastern District of New York to one count of conspiracy to violate the FCPA for his role in creating and executing false agreements to conceal bribes to officials from Petrobras and a governing Brazilian political party.4

SBM Offshore Settles with DOJ for $238 Million

On November 29, 2017, the DOJ announced that Netherlands-based offshore drilling equipment company SBM Offshore N.V. (SBM) entered into a DPA and its wholly owned US subsidiary entered a guilty plea to resolve an FCPA case involving improper payments to government officials in five countries. From 1996 until at least 2012, SBM paid more than $180 million in commissions to intermediaries, knowing that a portion of those commissions would be used to bribe foreign officials at state-owned oil companies in Brazil, Angola, Equatorial Guinea, Kazakhstan, and Iraq. Payments were made through bank accounts in the United States, Switzerland, Brazil, and Monaco. SBM reported at least $2.8 billion in revenue from the work it obtained from these state-owned oil companies.5

SBM agreed to pay a total criminal penalty of $238 million to the United States in addition to the $240 million in disgorged profits and fines that SBM agreed to pay Dutch authorities in 2014 to resolve a prosecution with respect to related misconduct. In calculating its fine, the DOJ took into account not only SBM's resolution with Dutch authorities but SBM's ongoing negotiations with Brazilian authorities, which may result in additional penalties. The DOJ further considered the need to avoid a penalty that would substantially jeopardize the continued viability of the company. The DOJ noted that, while SBM did not voluntary disclose the misconduct and the company's initial internal investigation did not uncover all the evidence of wrongdoing, SBM fully cooperated with the DOJ after the investigation was reopened and took significant remedial actions, including terminating or demoting employees who engaged in the misconduct, cleaning up its relationships with third-party agents, implementing a new compliance program, and hiring a full-time Chief Governance and Compliance Officer.6

As discussed below, two former SBM executives pleaded guilty to conspiracy to violate the FCPA for their roles in the bribery scheme, and two additional former SBM executives face bribery-related charges in the United Kingdom.

Telia Enters $965 Million Settlement with US, Swedish, and Dutch Authorities

On September 21, 2017, the DOJ and SEC announced that Swedish telecommunications company Telia Company AB (Telia) and its Uzbek subsidiary, Coscom LLC (Coscom), had agreed to pay a total of about $965 million to resolve foreign bribery charges with US, Dutch, and Swedish authorities—one of the largest global anti-bribery settlements of all time. Telia admitted that between 2006 and 2012 it paid approximately $331 million in bribes to an Uzbek official related to the then-President of Uzbekistan. Telia made the improper payments to a shell company known to be owned by Uzbek officials, including through accounts in New York, under the guise of payments for lobbying and consulting services that were never performed. In exchange for the bribes, Telia and Coscom received assistance with entering the Uzbek market and obtaining valuable telecommunications assets there.7

As part of a DPA resolving an FCPA conspiracy charge by the DOJ, Telia agreed to pay over $508 million in criminal penalties, including a $274 million criminal penalty that Telia agreed to pay the Public Prosecution Service of the Netherlands. According to the DOJ, Telia's cooperation and remediation resulted in a 25 percent reduction off the bottom of the US Sentencing Guidelines fine range. Coscom, for its part, pleaded guilty to a one-count criminal information charging the company with conspiracy to violate the FCPA.8

Through an administrative cease-and-desist order, Telia, which formerly issued securities in the United States, also agreed to pay a total of $457 million in disgorgement and interest to the SEC. The SEC stated that portions of the settlement could be offset by Telia's payments to Dutch and Swedish authorities, as well to the DOJ, provided that Telia pays at least $965 million in total.9

On September 22, 2017, a day after Telia's global settlement was announced, Swedish authorities filed related bribery charges against the former CEO of Telia, Lars Nyberg, as well as two other high-ranking Telia officials.10 Dutch telecommunications company VimpelCom Limited and its Uzbek subsidiary resolved bribery charges in 2016 in connection with payments to the same government official in Uzbekistan.

Alere Settles FCPA and Accounting Fraud Charges with SEC for $13 Million

On September 28, 2017, the SEC announced that Alere Inc. (Alere), a Massachusetts-based manufacturer and seller of diagnostic tests for infectious disease, cardiometabolic disease, and toxicology (which has since been acquired by Abbott Laboratories), agreed to pay $13 million to settle FCPA and accounting fraud charges. The SEC alleged, among other things, that Alere's Colombian subsidiary made improper payments of approximately $275,000 to a manager of a state-owned health insurance services provider in an effort to help Alere obtain and retain business. The SEC also alleged that Alere's Indian subsidiary, after winning a contract to provide malaria testing kits to a local governmental entity, used a distributor to pay local officials in India a four percent commission to increase orders under the contract. Alere, which did not admit or deny the SEC's allegations, consented to the entry of an administrative cease-and-desist order and agreed to pay $3.3 million in disgorgement, approximately $495,000 in interest, and a civil penalty of $9.2 million.11

SEC Settles FCPA Charges with Halliburton, Former Executive for $29.2 Million

On July 27, 2017, the SEC charged Texas-based Halliburton Company (Halliburton) with violating the books and records and internal accounting controls provisions of the FCPA in connection with winning lucrative oilfield services contracts from Angola's state oil company, Sonangol. According to the SEC, Halliburton made millions of dollars in payments to a local Angolan company owned by a former Halliburton employee who was a friend and neighbor of the Sonangol official responsible for awarding the contracts to Halliburton. Halliburton's contracts with the local Angolan company allegedly were intended to meet local content requirements rather than for the stated scope of work, and Halliburton's selection of and payments to the company allegedly circumvented internal accounting controls.

Without admitting or denying the charges, Halliburton agreed to an order requiring a settlement payment of approximately $29.2 million, including $14 million in disgorgement, $1.2 million in interest, and $14 million in penalties. Halliburton also agreed to the retention of an independent compliance consultant to oversee its anti-corruption policies and procedures in Africa. Without admitting or denying the SEC's claims, Halliburton's former vice president Jeannot Lorenz also agreed to pay a $75,000 penalty to settle charges that he caused the company's violations, circumvented internal accounting controls, and falsified books and records.12

Walmart Reserves for FCPA Settlement

U.S-based retailer Wal-Mart Stores, Inc. (Walmart) recently set aside roughly $283 million for a possible resolution of two ongoing investigations by the DOJ and SEC into potential FCPA violations in Mexico, Brazil, China, India, and several other countries. Walmart disclosed its internal investigation to the DOJ and SEC in 2011, and, following a New York Times story published in April 2012, has faced related shareholder and derivative suits.13 A final resolution with US authorities has not yet been reached, but Walmart reportedly has already spent over $700 million on investigation and compliance program enhancement costs.14

Core Lab Receives DOJ Declination

Core Laboratories N.V. (Core Lab) disclosed in a periodic securities filing that in October 2017, the DOJ issued a declination letter advising the company that it had closed its inquiry into potential FCPA violations and would not be taking any enforcement action against the company.15 Core Lab, an Amsterdam-based oil services company, previously had disclosed that the DOJ and SEC had contacted the company in connection with their ongoing investigations of Unaoil Group (Unaoil), and that Core Lab was cooperating with US authorities.16 Core Lab's October 2017 filing did not mention the SEC investigation.

DOJ, SEC Decline to Take Action Against MTS Systems

In a quarterly earnings report filed with the SEC on August 7, 2017, MTS Systems Corporation (MTS), a Minnesota-based maker of military testing systems and industrial position sensors, reported that the DOJ and SEC had notified the company that they were closing their investigations into potential FCPA violations without taking any further actions.17 MTS first disclosed in March 2012 that it had begun an internal investigation into certain gift, travel, entertainment, and other expenses incurred in the Asia-Pacific region.18 The company voluntarily disclosed the matter to the DOJ and SEC, and, in January 2013, turned over the results of its investigation to US authorities.19 Starting in 2014, MTS also conducted an internal investigation into similar issues arising out of the company's Chinese operations, and updated the DOJ and SEC on the findings of that investigation.20 MTS reported that the remedial measures implemented by the company included changes to internal control procedures and the removal of certain persons employed in its Korean office.21

US Bribery Investigation into Net1 Ends

In a letter dated July 26, 2017, the DOJ advised Net 1 UEPS Technologies, Inc. (Net1), a South African-based alternative payments company, that it had closed its investigation into potential FCPA violations by the company.22 The DOJ and SEC launched FCPA investigations into the company in November 2012, after a competitor who had lost a bid for a contract from the South African Social Security Agency forwarded evidence to the DOJ, suggesting that the tender process had been tainted by corruption.23 In May 2015, the SEC informed Net1that it had dropped its own investigation.24

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II. FCPA Enforcement Actions Against Individuals

Individuals Plead Guilty in Rolls-Royce Bribery Probe

On November 7, 2017, criminal charges were unsealed in the US District Court for the Southern District of Ohio against five individuals for their alleged participation in a corruption scheme involving UK-based Rolls-Royce plc and its US subsidiary (together, Rolls-Royce), which last January agreed to an $800 million global settlement with US, UK, and Brazilian authorities.25

James Finley, a UK citizen residing in Taiwan and a former senior executive of Rolls-Royce, pleaded guilty on July 28, 2017 to one count of conspiracy to violate the FCPA and one count of violating the FCPA.26 Keith Barnett, a Texas resident and former Rolls-Royce regional director, pleaded guilty on December 20, 2016 to one count of conspiracy to violate the FCPA.27 Aloysius Johannes Jozef Zuurhout, a Dutch citizen and former Rolls-Royce sales employee, pleaded guilty on June 13, 2017 to one count of conspiracy to violate the FCPA.28 In connection with their guilty pleas, the former Rolls-Royce employees admitted that they participated in a long-running conspiracy to engage commercial advisors who would use their commission payments from Rolls-Royce to bribe government officials in a number of countries to help Rolls-Royce win business.29

The DOJ also announced that, on October 12, 2017, Petros Contoguris—a Greek citizen residing in Turkey and founder and chief executive officer of Gravitas & Cie. International Ltd., a commercial agent and advisor for oil and gas projects—was indicted on FCPA, money laundering, and conspiracy charge related to his work with Rolls-Royce. Contoguris allegedly received commission payments from Rolls-Royce and then passed on a portion of those payments to employees of an international engineering and consulting firm knowing that they would share the money with a Kazakh official in exchange for helping Rolls-Royce win contracts with Asia Gas Pipeline, a state-owned joint venture between national oil companies in Kazakhstan and China. Contoguris remains at large.30 Andreas Kohler, of Austria, who was managing director at the international engineering and consulting firm, pleaded guilty on June 6, 2017 to one count of conspiracy to violate the FCPA.31

Two Former SBM Executives Plead Guilty to Conspiracy to Violate the FCPA

In November 2017, Anthony Mace and Robert Zubiate—former executives of Netherlands-based offshore oil-and-gas company SBM—pleaded guilty in federal court in Houston, Texas to conspiracy to violate the FCPA in relation to their roles in a scheme to bribe foreign officials in Brazil, Angola, and Equatorial Guinea. Mace, of the United Kingdom, was SBM's CEO from 2009 to 2011 and a board member of SBM's US subsidiary. He admitted that he authorized payments in furtherance of the conspiracy and deliberately avoided learning that those payments were bribes. For his part, Zubiate, a US-based sales and marketing executive at SBM's US subsidiary, admitted that, between 1996 and 2012, he engaged in a bribery and kickback scheme through the use of a third-party sales agent in order to help SBM and its subsidiary win bids from government officials.32 As discussed above, SBM and its US subsidiary agreed to pay $238 million as part of a settlement with the DOJ.

Head of Chinese NGO and Former Foreign Minister of Senegal Charged with Bribing Officials in Chad and Uganda

In November 2017, the DOJ brought criminal charges in the Southern District of New York against Chi Ping Patrick Ho (aka Patrick C.P. Ho), the head of a Hong Kong-based NGO, and Cheikh Gadio, the former foreign minister of Senegal, in connection with a scheme to bribe high-level officials in Chad and Uganda in order to secure business advantages for a multi-billion dollar Chinese oil and gas conglomerate headquartered in Shanghai.33

The DOJ's complaint alleges that Ho, with assistance from Gadio, allegedly offered a $2 million bribe to the President of Chad in exchange for securing a business advantage for the Chinese energy company seeking to gain the exclusive rights to oil in Chad.34 In the Uganda scheme, which the government alleges began in the halls of the United Nations in New York in October 2014, Ho purportedly paid a $500,000 bribe to the minister of foreign affairs of Uganda, who recently completed his term as the President of the UN General Assembly, in order to help the Chinese company secure contracts in Uganda's energy sectors.35 Ho and Gadio each were charged with FCPA, money laundering, and conspiracy offenses.36

Another Individual Pleads Guilty to Bribery Involving PDVSA

On October 11, 2017, Fernando Ardila Rueda (Ardila), an owner of several Florida-based energy companies, pleaded guilty in the Southern District of Texas to charges that he violated and conspired to violate the FCPA in connection with payments to officials at Venezuela's state-owned energy company, Petroleos de Venezuela S.A. (PDVSA). Ardila admitted that from 2008 through 2014, he provided entertainment and offered improper payments to PDVSA purchasing analysts based on a percentage of the value of contracts that the PDVSA officials helped to award to the companies with which Ardila was affiliated.37 The DOJ had previously announced the guilty pleas of nine other individuals as part of a larger, ongoing investigation by the US government into bribery at PDVSA.

Retired US Army Colonel Indicted in Haiti Bribery Conspiracy

Joseph Baptiste, a retired US Army colonel, was charged by the DOJ in the District of Massachusetts, first by a complaint unsealed on August 29, 2017, and later by indictment on October 4, 2017, with violations of the FCPA and the Travel Act, along with participating in a money laundering conspiracy. The charges arose out of an alleged bribery scheme involving a proposed $84 million project to develop a port in the Moles Saint Nicolas area of Haiti.38 The complaint alleges that during a recorded meeting at a Boston-area hotel, Baptiste solicited bribes from undercover agents who posed as potential investors in Haitian infrastructure. Baptiste allegedly told the agents that he would secure government approval of the port project by funneling illicit payments to Haitian officials through a Maryland-based nonprofit entity that he controlled.39 According to the complaint, Baptiste ultimately diverted for his own personal use the $50,000 that the undercover agents wired to the nonprofit, but he intended to seek additional funds from the agents to fund future bribes in connection with the port project.40

When first approached by federal agents in December 2015, Baptiste signed a sworn declaration and agreed to waive indictment and plead guilty to conspiracy to violate the FCPA and Travel Act.41 In more recent proceedings, however, Baptiste has changed course and stated that he does not intend to plead guilty.42 As of the date of publication, Baptiste remains free on bond with travel restrictions, and the case has been continued to February 26, 2018.43

Former Telecom Executive and Fugitive Sentenced to Time Served for Role in Haitian Conspiracy

In September 2017, Amadeus Richers, the former general manager of a Miami-based telecommunications company, was sentenced in federal court in Miami to time served for his role in a scheme to pay $3 million in bribes to Haitian officials to secure a contract with Haiti's state-owned telecommunications company.44 Richers was indicted on July 12, 2011, on multiple FCPA and money-laundering charges,45 but remained a fugitive until his extradition from Panama in February 2017.46 In July 2017, Richers pleaded guilty to one count of conspiracy to violate the FCPA.47 Richers admitted that between 2001 and 2004, he and his co-conspirators paid roughly $3 million in bribes directly and indirectly to foreign officials employed by the state-owned company, Telecommunications D'Haiti (Haiti Teleco).48 Richers is the ninth defendant sentenced in the Haiti Teleco case.

French Citizen and Former Alstom Executive Sentenced to 30 Months in Prison for Bribing Indonesian Officials

In September 2017, a Connecticut federal judge sentenced Frederic Pierucci, a former Alstom Power, Inc. executive, to 30 months in prison for his involvement in a scheme to pay bribes to Indonesian officials in exchange for assistance in securing a $118 million contract to provide power-related services in Indonesia.49 While the transcript of the sentencing hearing and presentencing filings are under seal, Pierucci's attorneys reportedly were seeking a sentence of time served. District Judge Janet Bond Arterton gave Pierucci credit for the 14 months he already had spent in federal detention, but stated that she did not consider time served to carry sufficient deterrent effect and wanted the sentence to send "the message that the FCPA and the OECD Convention are to be taken seriously."50 Judge Arterton also ordered Pierucci to pay a $20,000 fine.

Pierucci, a French citizen, pleaded guilty on July 29, 2013 to one count of conspiring to violate the FCPA and one count of violating the FCPA.51 Pierucci and three other former Alstom executives, Lawrence Hoskins, William Pomponi, and David Rothschild, retained purportedly legitimate consultants for the primary purpose of paying bribes to Indonesian officials, including a member of the Indonesian Parliament and officials in Indonesia's state-owned electricity company.52 Hoskins' trial has been stayed pending a Second Circuit ruling on the FCPA's reach over nonresident foreign nationals.53 Pomponi pleaded guilty to one charge of conspiracy to violate the FCPA in July 2014 but died prior to sentencing.54 Rothschild also pleaded guilty to conspiracy to violate the FCPA in November 2012 but has not yet been sentenced.55

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III. Other FCPA Investigation and Enforcement News

DOJ Announces New FCPA Corporate Enforcement Policy

On November 29, 2017, Deputy Attorney General Rod Rosenstein unveiled a revised Corporate Enforcement Policy for the FCPA.56 This policy, which incorporates key portions of the Obama Administration's FCPA Pilot Program into the US Attorneys' Manual, is "aimed at providing additional benefits to companies based on their corporate behavior once they learn of misconduct."57

The FCPA Corporate Enforcement Policy provides that "[w]hen a company has voluntarily self-disclosed misconduct in an FCPA matter, fully cooperated, and timely and appropriately remediated …, there will be a presumption that the company will receive a declination." Aggravating circumstances—such as where a high-level executive is involved in the misconduct, the company enjoyed significant profit from the misconduct, or the misconduct was pervasive—may overcome the presumption against prosecution. In those cases, companies still may receive a 50 percent reduction off the low end of the US Sentencing Guidelines fine range (except in the case of a criminal recidivist). Companies also may avoid the appointment of a compliance monitor if, at the time of the resolution, they have in place an effective compliance program. Notably, to qualify for favorable treatment under the Policy, a company must pay all disgorgement, forfeiture, and/or restitution from the misconduct at issue, even if the DOJ declines to bring charges.58

The FCPA Corporate Enforcement Policy also provides credit for full cooperation and timely and appropriate remediation in FCPA matters without voluntary self-disclosure. Consistent with the FCPA Pilot Program that was announced in April 2016, companies that satisfy the DOJ's standards for cooperation and remediation are eligible for a reduction of up to 25 percent off the low end of the Sentencing Guidelines fine range.59

The Policy defines what the DOJ considers "voluntary self-disclosure," "full cooperation," and "timely and appropriate remediation." To receive credit for self-disclosure, a company must report the issue before "an imminent threat of disclosure or government investigation," and must report all relevant facts known to the company at that time. Meanwhile, "full cooperation" requires that a company not only disclose the findings of any independent or internal investigations and any relevant documents and information, but also, if requested, the company must "deconflict" by deferring the interviews of employee witnesses or other investigative steps until after the government has had an opportunity to do so itself. Full credit for "timely and appropriate remediation" will be awarded only to companies that have analyzed and redressed the root causes of the misconduct, implemented an effective compliance program, appropriately disciplined any employees that participated in the misconduct, and taken steps that "demonstrate recognition of the company's misconduct," including acceptance of responsibility.60

The DOJ's FCPA Corporate Enforcement Policy makes permanent many of the core elements of the Pilot Program, which has guided the DOJ's FCPA enforcement decisions over the past year and a half.61 What is new is the presumption in favor of non-prosecution when companies self-report, cooperate, and remediate. This presumption is intended to encourage more self-reporting of violations.

SEC News

While the SEC welcomed new Chairman Jay Clayton in May, this year also brought other new leaders to the SEC's FCPA enforcement program. On November 2, 2017, agency veteran Charles Cain was officially named Chief of the SEC's FCPA Unit.62 Cain, one of the co-authors of the Resource Guide to the US Foreign Corrupt Practices Act, published by the DOJ and SEC in 2012, previously had served as Acting Chief of the FCPA Unit and Deputy Chief of the Unit.

In November, Steven Peikin, who was named Co-Director of the SEC's Division of Enforcement in June 2017, made public remarks regarding the SEC's continued commitment to robust enforcement. He addressed the US Supreme Court's recent decision in Kokesh v. SEC, which held that any claim for disgorgement in an SEC enforcement action must be commenced within five years of the date the claim accrued. Peikin told an audience at New York University Law School that "We have no choice but to respond by redoubling our efforts to bring cases as quickly as possible."63

Various Companies Announce New and Expanded Investigations Into Foreign Bribery Allegations

In the latter half of 2017, several companies disclosed investigations into potential FCPA violations. For example, on August 4, 2017, Teradata Corporation, a data and cloud technology firm based in Dayton, Ohio, reported that it discovered potential FCPA violations at one of its subsidiaries doing business in Turkey.64 On August 9, 2017, Stericycle, Inc., an Illinois-based firm that handles medical waste, disclosed that it had received a subpoena from the SEC relating to its Latin American operations and that the DOJ is also conducting a related investigation.65 On August 29, 2017, The Wall Street Journal reported that the DOJ has taken "preliminary steps" to investigate whether managers at Uber Technologies Inc. violated the FCPA.66 On September 7, 2017, Italian multinational oil and gas company Eni S.p.A. disclosed that a corruption investigation that had started three years ago in Nigeria has expanded to Algeria, the Republic of Congo, Kazakhstan, and Kuwait.67

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IV. Corruption-Related Legal Developments

Former FIFA Officials Convicted

Following a six-week trial, on December 22, 2017, a jury in a federal court in Brooklyn, New York convicted two former officials of the Fédération Internationale de Football Association (FIFA) of racketeering conspiracy, wire fraud conspiracy, and related federal crimes. The defendants, Juan Ángel Napout and José Maria Marin, accepted millions in bribes in return for marketing and media rights to South American soccer tournaments, laundering much of the money through the United States. The same jury acquitted defendant Manuel Burga, a former member of the FIFA Development Committee, of racketeering conspiracy, the sole count he faced.68 More than 20 other officials from FIFA and related organizations already have pleaded guilty to federal charges in connection with a wide-ranging corruption scandal involving international soccer.69

Second Circuit Declines to Reconsider Decision on the Use of Compelled Testimony

On November 9, 2017, the US Court of Appeals for the Second Circuit refused to reconsider a decision with far-reaching implications for cross-border enforcement efforts.70

In July 2017, a three-judge panel from the Second Circuit held that statements made to foreign officials under compulsion, even if legal and admissible in those foreign jurisdictions, cannot be used in US criminal proceedings.71 The defendants-appellants in the case, Anthony Allen and Anthony Conti, former employees of a Dutch bank, were convicted of wire fraud and conspiracy to commit wire fraud and bank fraud in connection with an alleged scheme to rig the London Interbank Offered Rate (LIBOR). At trial, prosecutors relied heavily on evidence provided by Paul Robson, one of Allen and Conti's former co-workers who cooperated with the DOJ.72 Allen, Conti, and Robson—all British citizens—previously had been under parallel investigations in the United Kingdom by the Financial Conduct Authority (FCA). As part of those investigations, Allen and Conti had been forced to speak to FCA officials under threat of jail.73 When the FCA initiated an enforcement action against Robson, in accordance with its standard procedures, the FCA disclosed the relevant testimony against him, including the compelled testimony of Allen and Conti.74

Holding that the Fifth Amendment protection against self-incrimination prohibits the use and derivative use of compelled testimony in American criminal proceedings, the Second Circuit reversed the convictions and dismissed the indictments against Allen and Conti. The Court further held that, "[w]hen the government uses a witness who has been substantially exposed to a defendant's compelled testimony, it is required … to prove, at a minimum, that the witness's review of the compelled testimony did not shape, alter, or affect the evidence used by the government."75 The Second Circuit's decision to deny the DOJ's petition for rehearing in the case means the government must choose between adapting to these evidentiary limitations in cross-border enforcement actions or seeking a writ for certiorari from the US Supreme Court.

Companies Settle Securities Litigation Involving Bribery in Brazil

On September 15, 2017, a federal judge in New York preliminarily approved a $10 million settlement of a securities class action suit against Brazilian petrochemical company Braskem SA (Braskem), whose American Depository Receipts trade publicly on the New York Stock Exchange. Investors sued Braskem in 2015, alleging, among other things, that the company had failed to disclose millions of dollars of improper payments to officials at Brazilian oil giant Petrobras in exchange for lower prices on an ingredient used in Braskem's petrochemicals.76 In December 2016, Braskem pleaded guilty to conspiring to violate the FCPA and agreed to pay $957 million in sanctions last year as part of a broader settlement involving its parent company, Odebrecht S.A.77

On January 3, 2018, Petrobras announced an agreement to pay $2.95 billion to settle securities class-action litigation pending in US District Court for the Southern District of New York.78

Ex-Guinea Minister Sentenced to Seven Years in Prison

On August 25, 2017, a federal judge in the Southern District of New York sentenced Mahmoud Thiam, the former Guinean Minister of Mines and Geology, to seven years in prison. The Court also ordered Thiam to forfeit $8.5 million, the amount of bribes that he took in exchange for mineral rights while a government official in Guinea.79

Thiam, who is a US citizen, was found guilty in May of one count of money laundering and one count of conducting transactions in criminally derived property.80 At trial, the evidence showed that, from 2009 to 2011, Thiam accepted $8.5 million from executives of China Sonangol International Ltd. and China International Fund, SA. The money was paid to a bank account in Hong Kong in exchange for help in securing agreements with the Guinean government for lucrative mining and investment rights.81 Thiam then transferred roughly $3.9 million to the United States through bank accounts and other means. Thiam is appealing his conviction to the US Court of Appeals for the Second Circuit.82

Former Director of South Korea's Earthquake Research Center Convicted of Laundering Bribe Money

On July 18, 2017, a federal jury in California convicted Heon-Cheol Chi, a former director of South Korea's Earthquake Research Center at the Korea Institute of Geoscience and Mineral Resources (KIGAM), of money laundering. Between at least 2009 and 2015, Chi received over a million dollars in bribes from seismological companies based in California and the United Kingdom in exchange for business advantages, including inside information about South Korean KIGAM contracts. He used accounts in California and New York to launder the funds and instructed his contacts to delete emails discussing the transactions in order to conceal the scheme. A federal judge sentenced Chi to 14 months in prison and ordered him to pay a $15,000 fine.83

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UK SFO Charges Four in Connection with Unaoil Probe

In November, the UK Serious Fraud Office (SFO) announced criminal charges against four individuals as part of its ongoing investigation into alleged bribery and corruption at Unaoil, a Monaco-based oil and gas services company.84 On November 16, 2017, the SFO charged Ziad Akle and Basil Al Jarah with conspiracy to make corrupt payments, allegedly in order to secure contracts for Unaoil's client SBM in Iraq.85 The SFO described Akle as Unaoil's territory manager for Iraq and Al Jarah as Unaoil's Iraq partner.

On November 30, 2017, the SFO announced that it had charged two former SBM Offshore executives, Paul Bond and Stephen Whiteley, with conspiracy to make corrupt payments as part of the same alleged Iraq bribery scheme.86 According to the SFO, Bond was formerly a Senior Sales Manager with SBM and Whiteley was formerly a Vice President with SBM and Unaoil's General Territories Manager for Iraq, Kazakhstan, and Angola. As discussed above, also in November, SBM and its US subsidiary agreed to pay $238 million as part of an FCPA settlement with the DOJ, while two additional former SBM executives pleaded guilty in federal court for conspiring to violate the FCPA.

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Three F.H. Bertling Employees Fined but Avoid Prison in UK for Angolan Bribery

At their October 20, 2017, sentencing before Judge Jeffrey Pegden of the Southwark Crown Court, three former employees of freight-forwarding company F.H. Bertling Ltd. were ordered to pay fines but will avoid prison time for conspiring to make corrupt payments to secure a $20 million contract in Angola.87 The court sentenced Joerg Blumberg, Dirk Juergensen, and Marc Schweiger, all German nationals, to 20 months in prison, but suspended those sentences for two years.

The men, who pleaded guilty in March 2017, also were fined £20,000 and disqualified from serving as company directors for five years. Some anti-corruption advocates criticized the sentences as overly lenient, with Transparency International UK publicly stating that the penalties imposed in the case "fall well short of what is necessary to act as a serious deterrent against UK companies engaging in corrupt activities abroad."88

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Swedish Court Finds Bombardier Employee Not Guilty of Bribery in Azerbaijan Railway Project

On October 11, 2017, a district court in Stockholm, Sweden, found former Bombardier Transportation Sweden AB (Bombardier) employee Evgeny Pavlov not guilty of "aggravated bribery" in connection with a $340 million railway contract awarded to Bombardier's local partner in Azerbaijan in 2013.89 Swedish prosecutors alleged that Pavlov and other Bombardier employees bribed Azerbaijani officials "in order to adapt [the] contract" for a new train signaling system to fit Bombardier.90 The court, which focused its ruling narrowly on Pavlov's role in founding Trans-Signal-Rabita, Bombardier's local partner in the consortium that won the bid, found that "[t]he prosecutors have not proved that [Pavlov] has promised or offered an inappropriate benefit."91 The Swedish National Anti-Corruption Unit continues to investigate five other Bombardier employees involved with the railway project.92 In addition, the World Bank, which provided 85 percent of the project's funding, is undertaking a separate audit of the contract.93

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Shell, Eni, and 15 Executives to Face Trial in Italy in $1 Billion Nigerian Bribery Case

On March 5, 2018, trial will begin in Milan, Italy, against Royal Dutch Shell and Eni S.p.A, which each face charges of bribery and corruption relating to a 2011 Nigerian oil deal.94 Fifteen individuals, including Eni's former and current CEOs, Claudio Descalzi and Paolo Scaroni, as well as former Shell UK Chairman Malcolm Brinded, will also stand trial for their alleged roles in one of the oil industry's largest corruption scandals in history.95 The Milan Public Prosecutor's Office alleges that the companies' deal to purchase the offshore oil tract called OPL 245 for $1.3 billion in 2011 amounted to a massive bribe to then-present and former Nigerian officials.96 The trial is expected to last eighteen months, and the decision can be appealed first to the Court of Appeal of Milan, then to the Italian Supreme Court or Court of Cassation, so a definitive verdict in the case is not likely for several years.97

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*Seth Grantier contributed to this newsletter. Mr. Grantier is a graduate of Brooklyn Law School and is employed at Arnold & Porter Kaye Scholer LLP's New York office. Mr. Grantier is not admitted to the practice of law in New York.

© Arnold & Porter Kaye Scholer LLP. This newsletter is intended to be a general summary of the law and does not constitute legal advice. You should consult with counsel to determine applicable legal requirements in a specific fact situation.

  1. Arnold & Porter Kaye Scholer, "Global Anti-Corruption Insights: Summer 2017," Aug. 2, 2017 {hereinafter "APKS Summer 2017 Newsletter"}.

  2. Press Release, DOJ, Keppel Offshore & Marine Ltd. and U.S. Based Subsidiary Agree to Pay $422 Million in Global Penalties to Resolve Foreign Bribery Case (Dec. 22, 2017).

  3. Id.

  4. Id.; Information, United States v. Chow, No. 1:17-cr-00466-KAM (E.D.N.Y. Aug. 29, 2017), Dkt. Entry No. 2.

  5. Press Release, DOJ, SBM Offshore N.V. And United States-Based Subsidiary Resolve Foreign Corrupt Practices Act Case Involving Bribes in Five Countries (Nov. 29, 2017).

  6. See id.; see also Deferred Prosecution Agreement, United States v. SBM Offshore, Cr. No. 17-686 (S.D. Tex. Nov. 29, 2017).

  7. Press Release, DOJ, Telia Company AB and Its Uzbek Subsidiary Enter Into a Global Foreign Bribery Resolution of More Than $965 Million for Corrupt Payments in Uzbekistan (Sept. 21, 2017).

  8. Id.

  9. Press Release, SEC, Telecommunications Company Paying $965 Million For FCPA Violations (Sept. 21, 2017).

  10. Reuters Staff, "UPDATE 2-Former Telia CEO Charged With Bribery in Uzbekistan Probe," Reuters, Sept. 22, 2017.

  11. See Order Instituting Cease-and-Desist Proceedings, Pursuant to Section 8a of the Securities Act of 1933 and Section 21c of the Securities Exchange Act Of 1934, Making Findings, and Imposing a Cease-and-Desist Order, In the Matter of Alere Inc., Exchange Act Release No. 81742 (Sept. 28, 2017).

  12. Press Release, SEC, Halliburton Paying $29.2 Million to Settle FCPA Violations (July 27, 2017).

  13. Wal-Mart Stores, Inc., Quarterly Report (Form 10-Q), at 16-17, 35 (Dec. 1, 2017).

  14. See Jon Hill, "Walmart Puts Aside $283M For Potential FCPA Settlement," Law360, Nov. 16, 2017.

  15. Core Laboratories N.V., Quarterly Report (Form 10-Q), at 23-24 (Oct. 24, 2017).

  16. Core Laboratories N.V., Quarterly Report (Form 10-Q), at 26 (July 22, 2016); Core Laboratories N.V., Annual Report (Form 10-K), at 28 (Feb. 10, 2017).

  17. MTS Systems Corp., Quarterly Report (Form 10-Q), at 47 (Aug. 7, 2017); see also Samuel Rubenfeld, U.S. Drops Bribery Probe of MTS Systems, Wall St. J., Aug. 10, 2017.

  18. MTS Systems Corp., Current Report (Form 8-K), at 2 (Mar. 27, 2012); see also Samuel Rubenfeld, MTS Systems Discloses Internal FCPA Probe, Wall St. J., Apr. 2, 2012.

  19. MTS Systems Corp., Quarterly Report (Form 10-Q), at 35 (May 6, 2013); see also Christopher M. Matthews, "MTS Reports FCPA Probe Findings to Feds," Wall St. J., May 8, 2013.

  20. See MTS Systems Corp., Quarterly Report, supra note 19, at 47.

  21. Id.

  22. Letter from Daniel Kahn, Deputy Chief, Fraud Sec., DOJ, to John Hillebrecht, DLA Piper LLP (July 26, 2017).

  23. Press Release, Net1, Net1 Announces Closure of FCPA Investigation by U.S. Department of Justice (July 27, 2017); see also Net 1 UEPS Technologies, Inc., Current Report (Form 8-K), at 1 (Dec. 4, 2012).

  24. Letter from Charles Cain, Deputy Chief, FCPA Unit, SEC, to Patrick Smith, DLA Piper LLP (May 29, 2015).

  25. See Press Release, DOJ, Five Individuals Charged in Foreign Bribery Scheme Involving Rolls-Royce Plc and Its U.S. Subsidiary (Nov. 7, 2017) {hereinafter "DOJ Rolls-Royce Individuals Release"}.

  26. Information, United States v. Finley, No. 2:17-cr-00160-EAS (S.D. Ohio, July 21, 2017), Dkt. Entry 3.

  27. Information, United States v. Barnett, No. 2:16-cr-00248-EAS (S.D. Ohio, Dec. 20, 2016), Dkt. Entry 3.

  28. Information, United States v. Zuurhout, No. 2:17-cr-00122-EAS (S.D. Ohio, June 9, 2017), Dkt. Entry 3.

  29. See DOJ Rolls-Royce Individuals Release, supra note 25

  30. Indictment, United States v. Contoguris, No. 2:17-cr-00233-EAS (S.D. Ohio, Oct. 12, 2017), Dkt. Entry 3.

  31. Information, United States v. Kohler, No. 2:17-cr-00113-EAS (S.D. Ohio, June 6, 2017), Dkt. Entry 3

  32. Press Release, DOJ, Two Executives Plead Guilty to Role in Foreign Bribery Scheme (Nov. 9, 2017); see also Dave Simpson, "2 Ex-SBM Execs Cop To FCPA Charges In Petrobras Scheme," Law360, Nov. 9, 2017.

  33. See Complaint, United States v. Ho, No. 1:17-mj-08611-UA (S.D.N.Y Nov. 16, 2017), Dkt. Entry 1 {hereinafter "Ho/Gadio Complaint"}; Press Release, DOJ, Head Of Organization Backed By Chinese Energy Conglomerate, And Former Foreign Minister Of Senegal, Charged With Bribing High-Level African Officials (Nov. 20, 2017).

  34. See Ho/Gadio Complaint, supra note 33, at ¶¶ 21-31.

  35. See id. at ¶¶ 32-46.

  36. Id.

  37. See Press Release, DOJ, Florida Businessman Pleads Guilty to Foreign Bribery Charges in Connection With Venezuela Bribery Scheme (Oct. 11, 2017).

  38. See Press Release, DOJ, Retired U.S. Army Colonel Charged With Conspiring to Bribe Senior Officials of the Republic of Haiti (Aug. 29, 2017).

  39. See Indictment, United States v. Baptiste, No. 17-cr-10305-ADB (D. Mass. Oct. 4, 2017), Dkt. Entry 13.

  40. See id.

  41. Sealed Complaint, United State v. Baptiste, No. 17-cr-10305-ADB (D. Mass. Aug. 28, 2017), Dkt. Entry 3-2, ¶ 31.

  42. Id.

  43. Order on Excludable Delay, United States v. Baptiste, No. 17-cr-10305-ADB (D. Mass. Dec. 19, 2017), Dkt. Entry 34.

  44. See Judgment, United States v. Richers, No. 09-cr-21010-JEM (S.D. Fl. Sept. 25, 2017), Dkt. Entry 988.

  45. Superseding Indictment, United States v. Esquenazi, No. 1:09-cr-21010-JEM-7 (July 12, 2011), Dkt. Entry 419.

  46. See Press Release, DOJ, Telecom Executive Pleads Guilty to FCPA Charge in Connection With Haitian Bribery (July 19, 2017).

  47. Plea Agreement, United States v. Richers, No. 09-cr-21010-JEM (S.D. Fl. Jul. 19, 2017), Dkt. Entry 976.

  48. Id.

  49. See Judgment, United States v. Pierucci, No. 3:12-cr-00238-JBA (D. Conn. Oct. 12, 2017), Dkt. Entry 416.

  50. See Jody Godoy, "Judge Sends "Message" in Ex-Alstom Exec's Bribery Sentence," Law360, Sept. 25, 2017.

  51. Plea Agreement, United States v. Pierucci, No. 3:12-cr-00238-JBA (D. Conn. July 29, 2013), Dkt. Entry 46.

  52. See Press Release, DOJ, Former Senior Executive of French Power Company Charged in Connection with Foreign Bribery Scheme (July 30, 2013).

  53. For more details on United States v. Pierucci (Hoskins), No. 16-1010 (2d Cir.), see Arnold & Porter Kaye Scholer, "Global Anti-Corruption Insights: Winter 2017," Feb. 6, 2017 {hereinafter "APKS Winter 2017 Newsletter"}.

  54. Motion to Dismiss as to William Pomponi, United States v. Pierucci, No. 3:12-cr-00238-JBA (D. Conn. July 6, 2016), Dkt. Entry 350.

  55. Plea Agreement, United States v. Rothschild, No. 3:12-cr-00223-JBA (D. Conn. Nov. 2, 2012), Dkt. Entry 8.

  56. Justice Dep't, News, Deputy Attorney General Rosenstein Delivers Remarks at the 34th International Conference on the Foreign Corrupt Practices Act.

  57. US Attorneys' Manual (USAM) § 9-47.120.

  58. USAM § 9-47.120.

  59. See id.

  60. See id.

  61. For a discussion of the FCPA Pilot Program and its implementation, see APKS Summer 2017 Newsletter, supra note 1; APKS Winter 2017 Newsletter, supra note 53.

  62. Press Release, SEC, Charles Cain Named Chief of Foreign Corrupt Practices Unit (Nov. 2, 2017).

  63. Richard Satran, "U.S. foreign bribery cases fast-tracked due to statute of limitations ruling – SEC enforcement chief," Reuters, Nov. 15, 2017.

  64. See Teradata Corporation, Quarterly Report (Form 10-Q) (Aug. 4, 2017).

  65. See Stericycle, Inc., Quarterly Report (Form 10-Q) (Aug. 9, 2017).

  66. See Douglas MacMillan and Aruna Viswanatha, "Uber Faces Investigation of Possible Foreign-Bribery-Law Violations," Wall St. J., Aug. 29, 2017.

  67. See Eni S.p.A., Report of Foreign Issuer (Form 6-K) (Sept. 7, 2017).

  68. Press Release, DOJ, High-Ranking Soccer Officials Convicted in Multi-Million Dollar Bribery Schemes (Dec. 26, 2017).

  69. See Press Release, DOJ, Sixteen Additional FIFA Officials Indicted for Racketeering Conspiracy and Corruption (Dec. 3, 2015).

  70. Order, United States v. Allen, No. 16-898 (2d Cir. Nov. 9, 2017), Dkt. Entry 139.

  71. Opinion, United States v. Allen, No. 16-898 (2d Cir. July 19, 2017), Dkt. Entry 98-1.

  72. Id. at 27-29.

  73. Id. at 25.

  74. Id. at 26.

  75. Id. at 80 (citing Kastigar v. United States, 406 U.S. 441 (1972)).

  76. Order on Motion for Settlement, In re Braskem Sec. Litig., 1:15-cv-05132 (S.D.N.Y. Sept. 15, 2017), Dkt. Entry No. 124; Settlement, In re Braskem Sec. Litig., 1:15-cv-05132 (S.D.N.Y. Sept. 14, 2017), Dkt. Entry No. 122. See also Samuel Rubenfeld, "Braskem Signs $10 Million Settlement Over Bribery Scandal," Wall St. J., Sept. 14, 2017.

  77. Press Release, DOJ, Odebrecht and Braskem Plead Guilty and Agree to Pay at Least $3.5 Billion in Global Penalties to Resolve Largest Foreign Bribery Case in History (Dec. 21, 2016).

  78. Petrobras, Report of Foreign Issuer (Form 6-K) (Jan. 3, 2018).

  79. Judgment in a Criminal Case, United States v. Thiam, No. 1:17-cr-00047-DLC (S.D.N.Y. Aug. 28, 2017), Dkt. Entry 136.

  80. Id.

  81. Press Release, DOJ, Former Guinean Minister of Mines Convicted of Receiving and Laundering $8.5 Million in Bribes from China International Fund and China Sonangol, No. 17-493 (May 4, 2017); see also Press Release, DOJ, Former Guinean Minister of Mines Sentenced to Seven Years in Prison for Receiving and Laundering $8.5 Million in Bribes From China International Fund and China Sonangol, No. 17-939 (Aug. 25, 2017).

  82. Notice of Criminal Appeal, United States v. Thiam, No. 17-2765 (2d Cir. Sept. 5, 2017), Dkt. Entry 1.

  83. See Press Release, DOJ, Director of South Korea's Earthquake Research Center Sentenced to 14 months in Federal Prison for Money Laundering Stemming from Million Dollar Bribe Scheme (Oct. 2, 2017).

  84. For additional background on the SFO's Unaoil investigation, see APKS Summer 2017 Newsletter, supra note 1.

  85. Press Release, SFO, Two Charged in SFO's Unaoil Investigation (Nov. 16, 2017). A third Unaoil executive, Saman Ahsani, described as Unaoil's Commercial Director, was not charged but is subject to an extradition request to Monaco on related charges.

  86. Press Release, SFO, Two Further Individuals Charged in SFO's Unaoil Investigation (Nov. 30, 2017).

  87. See, e.g., Press Release, SFO, Three Men Sentenced in $20m Angolan Oil Corruption Case (Oct. 20, 2017); Henry Cutter, "3 Fined in F.H. Bertling Bribery Case,"Wall St. J., Oct. 20, 2017.

  88. Press Release, Transparency Int'l UK, Sentences in $20M Angolan Oil Corruption Case Do Not Reflect Seriousness of the Crime (Oct. 20, 2017).

  89. Mark MacKinnon, Swedish Court Acquits Bombardier Employee in Bribery Case, The Globe and Mail, Oct. 11, 2017.

  90. CBC News, "Bombardier employee arrested, others questioned in Swedish bribery probe," CBC News, Mar. 10, 2017; see also Reuters Staff, "Swedish court rules Bombardier employee not guilty of bribery," Reuters (Oct. 11, 2017).

  91. MacKinnon, supra note 89.

  92. Reuters Staff, supra note 90.

  93. MacKinnon, supra note 89.

  94. Stanley Reed, "Shell and Eni to Be Tried Over $1.3 Billion Nigerian Oil Deal," N.Y. Times, Dec. 20, 2017.

  95. Eric Sylvers & Sarah Kent, "Shell, Eni Face Italian Charges Over Nigerian Deal," Wall St. J., Dec. 20, 2017.

  96. See, e.g., Eric Sylvers & Sarah Kent, "Italian Prosecutors Request Eni CEO, Shell Stand Trial," Wall St. J., Feb. 8, 2017; Simon Jack, "Shell corruption probe: New evidence on oil payments," BBC News, Apr. 10, 2017.

  97. Sylvers & Kent, supra note 95.

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