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Harry Cassin
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What does this investigation disclosure mean?

The research team at FCPA Tracker reads stacks of SEC filings, and every FCPA investigation disclosure.

Sometimes we come across a disclosure that doesn’t fit into any category. That happened with the 10-K that World Fuel Services (or WFS) filed with the SEC on February 28.

It said in part:

On July 20, 2016, we were informed that the U.S. Department of Justice (the “DOJ”) is conducting an investigation into the aviation fuel supply industry, including certain activities by us and other industry participants at an airport in Central America. In connection therewith, we were served with formal requests by the DOJ about its activities at that airport and its aviation fuel supply business more broadly. We are cooperating with the investigation.

(The same disclosure also appeared in WFS’s October 31, 2017 10-Q, July 28, 2017 10-Q, and April 28, 2017 10-Q)

There’s some solid information in the disclosure. We know there’s an investigation, it involves an airport in Central America and the aviation fuel supply business, and the DOJ is looking into it.

But what’s being investigated? Is it an FCPA-related problem? Is it restraint of trade? Is it funny business with customs agents, or tax collectors?

The disclosure doesn’t answer those questions. And World Fuel Services doesn’t say whether or not the outcome of the investigation might harm the company or its business.

According to its website, WFS provides “energy procurement advisory services, supply fulfillment, and transaction and payment management solutions to commercial and industrial customers, principally in the aviation, marine and land transportation industries.”

It’s currently #103 on the Fortune 500, with $33.7 billion in annual revenue. And it operates from 150 offices in 190 countries, employing over 5,000 people.

I reached out to the company on March 1, asking for clarification about their disclosure, and specifically if it’s related to the FCPA.

They sent back an automated reply saying a World Fuel Services representative would be in contact with me shortly.

A day passed, then two, then four. No word yet from the company.

World Fuel Services says on page six of its Code of Conduct that it’s “committed to doing the right thing.”

“We communicate this commitment to our customers, business partners, investors, and communities by acting with honesty and integrity in all that we do.”

I’m still hoping to hear back from the company soon.

I’ll post my progress.


Harry Cassin is the CEO of Recathlon LLC, the parent company of the FCPA Blog and FCPA Tracker.

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