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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

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

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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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DOJ declination for Hyperdynamics

Hyperdynamics Corporation said Friday the DOJ has closed its FCPA investigation without bringing any charges against the company.

The Houston-based oil and gas company said it had cooperated with the government’s investigation, and the “DOJ noted the value of the Company’s cooperation in its [declination] letter.”

Hyperdynamics received a subpoena from the DOJ in September 2013 requesting documents relating to its business in the African country of Guinea.

The company said then the investigation focused on whether its “activities in obtaining and retaining the Concession rights and [its] relationships with charitable organizations potentially violate the FCPA and anti-money laundering statutes.”

Charitable contributions can violate the FCPA if they benefit foreign officials personally and are intended to obtain or retain business or gain an unfair advantage.

Hyperdynamics Corporation trades in the over-the-counter market under the symbol HDYN. It previously traded on the New York Stock Exchange under the symbol HDY.

The company received notice in January this year from the NYSE that its shares, which traded at less than $1.00 over a consecutive 30 trading-day period, no longer met the NYSE listing requirements

Hyperdynamics spent about $7.5 million on the FCPA investigation, it said earlier.

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Here’s the DOJ’s May 21, 2015 declination letter to Hyperdynamics’ counsel:


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

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