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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
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Bill Waite
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

No penalties for Noble execs in SEC settlement

A former and a current executive of Noble Corporation settled with the SEC without paying any penalties, according to a stipulation filed with the federal district court in Houston Wednesday.

Mark Jackson, Noble’s former CEO, and William Ruehlen, head of the company’s Nigeria unit, were charged in February 2012 with bribing officials in Nigeria in exchange for illegal import permits for drilling rigs.

Jackson and Ruehlen were scheduled to go to trial July 9 for FCPA books and records offenses.

As reported first by Sam Rubenfeld of the Wall Street Journal, Jackson consented to an injunction for being a “control person” for Noble’s books and records violations, and Ruehlen consented to an injunction for aiding and abetting books and records violations.

“Neither admitted nor denied wrongdoing under the terms of the settlement documents, nor were they penalized in the case,” Rubenfeld said.

The SEC was “limited in its options for pursuing penalties over the alleged misconduct in the case . . . because of a Supreme Court case decided in 2013, after the charges were filed, that held the agency faced a five-year statute of limitations from the time it occurred, not from the time it was discovered, when seeking civil penalties in fraud cases,” the report said.

A third man, Thomas F. O’Rourke, Noble’s former controller and head of internal audit, settled the SEC’s civil charges in 2012 by paying a $35,000 penalty.

In 2010, Noble Corporation paid $8.1 million to settle FCPA offenses.

The DOJ and SEC said Noble paid $74,000 to a Nigerian freight forwarding agent, knowing that some of the payments would be passed on as bribes to Nigerian customs officials.

Noble falsely recorded the bribes as legitimate business expenses, the SEC said.


Richard L. Cassin is the publisher and editor of the FCPA Blog. He can be contacted here.

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