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Harry Cassin
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Andy Spalding
Senior Editor

Jessica Tillipman
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Bill Steinman
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Richard L. Cassin
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Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
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Thomas Fox
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Marc Alain Bohn
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Bill Waite
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Shruti J. Shah
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Russell A. Stamets
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Eric Carlson
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Halliburton continues multiple internal investigations

Oil field services giant Halliburton said this week its internal investigations into potential FCPA and conflict violations in Angola and Iraq are continuing, and the company is reporting all results to the DOJ and SEC.

In 2010, a whistleblower flagged potential violations through an Angolan vendor. The company then launched an investigation into those allegations.

Last year, Halliburton launched another unrelated investigation ‘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.’

Halliburton and its former subsidiary KBR settled FCPA violations In February 2009 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.

Jack Stanley, KBR’s former CEO, is now serving a 30-month sentence in a federal prison in eastern Arkansas.

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From Halliburton Company’s Form 10-K filed with the SEC on February 11, here’s the full FCPA disclosure.

All FCPA-relevant disclosures filed with the SEC are available from ethiXbase, the world’s biggest anti-corruption knowledge base.

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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