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Halliburton Opens New Investigation

Oil and gas services giant Halliburton said it has opened a new investigation into payments by operations in Angola and Iraq.

The payments to third-party agents were for customs clearance and visa issues.

Houston-based Halliburton said it told the DOJ and SEC earlier this year that it has begun the new FCPA investigation.

In 2010, a whistleblower alerted Halliburton to potential FCPA and conflict violations through an Angolan vendor. The company then launched an investigation into those allegations.

In February 2009, Halliburton and its former subsidiary KBR settled FCPA violations for $579 million, the second biggest FCPA-related settlement of all time. KBR admitted paying Nigerian officials at least $182 million in bribes on behalf of itself and three partners for contracts to build liquefied natural gas facilities on Bonny Island, Nigeria.

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Here’s Halliburton’s full FCPA disclosure from its Form 10-Q filed with the SEC on July 27:

We are conducting internal investigations of certain areas of our operations in Angola and Iraq, focusing on compliance with certain company policies, including our Code of Business Conduct (COBC), and the FCPA and other applicable laws.

In December 2010, we received an anonymous e-mail alleging that certain current and former personnel violated our COBC and the FCPA, principally through the use of an Angolan vendor. The e-mail also alleges conflicts of interest, self-dealing, and the failure to act on alleged violations of our COBC and the FCPA. We contacted the DOJ to advise them that we were initiating an internal investigation.

Since the third quarter of 2011, we have been participating in meetings with the DOJ and the SEC to brief them on the status of our investigation and have been producing documents to them both voluntarily and as a result of SEC subpoenas to the company and certain of our current and former officers and employees.

During the second quarter of 2012, in connection with a meeting with the DOJ and the SEC regarding the above investigation, we advised the DOJ and the SEC that we were initiating unrelated, internal investigations into payments made to a third-party agent relating to certain customs matters in Angola and to third-party agents relating to certain customs and visa matters in Iraq.

We expect to continue to have discussions with the DOJ and the SEC regarding the Angola and Iraq matters described above and have indicated that we would further update them as our investigations progress. We have engaged outside counsel and independent forensic accountants to assist us with the investigations. We intend to continue to cooperate with the DOJ’s and the SEC’s inquiries and requests in these investigations. Because these investigations are ongoing, we cannot predict their outcome or the consequences thereof.

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Research courtesy of ethiXbase, the world’s largest database of anti-corruption legislation, gift-giving regulations, investigations, and enforcement actions.

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