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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
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
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Bill Steinman
Contributing Editor

FCPA enforcement report for Q2 2015

From April through June, there were two corporate FCPA enforcement actions. There were also two individual guilty pleas, with one — by Joseph Sigelman in the midst of his FCPA trial — resulting in probation only and no jail time.

(Last year in Q2 there was one corporate enforcement action — Hewlett Packard’s $108 milion resolution.)

Over the past three months, there were four declinations. PetroTiger’s declination was announced in a rare public statement from the DOJ.

Here’s the full report for the second quarter of 2015:

DOJ / SEC Enforcement Resolutions

BHP Billiton (May 20) paid $25 million to the SEC to settle Olympics-related FCPA offenses. The SEC settled the case through an internal administrative action without going to court. The SEC said BHP improperly sponsored foreign government officials as guests at the 2008 Summer Olympics in Beijing.

IAP Worldwide Services (June 16) paid a $7.1 million criminal fine to settle FCPA offenses. The Florida-based defense and government contracting company resolved the DOJ’s investigation into an alleged conspiracy to bribe Kuwaiti officials to win a contract.

Gullty Pleas/Sentencing

Joseph Sigelman (June 15), the former co-CEO of PetroTiger, pleaded guilty to one criminal count of conspiracy to violate the FCPA during the third week of his FCPA trial. Sigelman, 44, was sentenced on June 16 to probation and no jail time. 

James Michael Rama (June 16), a former vice president of IAP (see above) pleaded guilty in federal court to one count of conspiracy to violate the anti-bribery provisions of the FCPA. Rama, 69, of Lynchburg, Virginia, is scheduled to be sentenced on September 11.

Declinations

Hyperdynamics Corporation (May 26) said the DOJ has closed its FCPA investigation without bringing any charges against the company. The Houston-based oil and gas company received a subpoena from the DOJ in September 2013 requesting documents relating to its business in the African country of Guinea.

Gold Fields Ltd. (June 24) issued a statement saying the SEC closed its FCPA investigation and won’t recommend an enforcement action against the company. The SEC launched its investigation of the South African miner in 2013. The allegation concerned the propriety of a nine percent stake granted by Gold Fields to the ruling ANC party chairwoman.

PetroTiger (June 16) was the subject of a public announcement by the DOJ after the guilty plea by former CEO Joseph Sigelman (see above). The DOJ said: “Based on PetroTiger’s voluntary disclosure, cooperation, and remediation, among other factors, the department declined to prosecute PetroTiger.”

Net 1 UEPS Technologies (June 1) said in a securities filing that the SEC isn’t recommending an enforcement action after investigating possible FCPA violations. South Africa-based Net1 said in December 2012 that the SEC, DOJ, and FBI were investigating payments to South African government officials to win a contract with the Social Security Agency. The company believes the DOJ investigation is ongoing.

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Here are some prior enforcement reports:

Enforcement Report for Q1 2015

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2014 FCPA Enforcement Index

2013 FCPA Enforcement Index

2012 FCPA Enforcement Index

2011 FCPA Enforcement Index

2010 FCPA Enforcement Index

2009 FCPA Enforcement Index

2008 FCPA Enforcement Index

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

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