Editors

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

Who did Unaoil work for?

Last week the DOJ revealed guilty pleas by the two Ahsani brothers who were running Monaco-based intermediary Unaoil. The brothers copped to a ten-country bribery conspiracy intended to help “multiple companies” win oil and gas-related contracts. So what companies did Unaoil work for?

According to data from FCPA Tracker, Unaoil has been identified as an intermediary in FCPA-related investigations involving these firms:

Honeywell International Inc.

Baker Hughes

John Wood Group PLC

TechnipFMC plc

SBM Offshore N.V.

Petrofac Limited

KBR, Inc.

FMC Technologies, Inc.

Core Laboratories N.V.

ABB Ltd

Four of the investigations have been closed following enforcement actions or declinations. Six remain open.

The agencies involved in the still-open investigations include the DOJ and SEC, along with the U.S. Internal Revenue Service, the U.S. Postal Inspection Service, the UK Serious Fraud Office, the Brazil Office of the Comptroller General, the Brazilian Federal Prosecutor’s Office, and the Scotland Crown Office.

Among the countries mentioned in company disclosures and agency releases about the open investigations are Brazil, South Africa, Algeria, Iran, Iraq, Angola, Azerbaijan, Kazakhstan, and Syria.

Unaoil itself is also the target of pending criminal and civil investigations.

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The DOJ information (charging document) against the Ahsani brothers said in addition to SBM Offshore and Rolls-Royce plc, 25 other  companies were part of the Unaoil bribe-paying conspiracy. The DOJ didn’t name the 25 companies.

Rolls-Royce reached a global settlement with prosecutors in the UK, the United States, and Brazil in January 2017 that required it to pay a combined total of about $809 million.

SBM Offshore paid the DOJ a criminal penalty of $238 million in November 2017 to resolve FCPA offenses in Brazil, Angola, Equatorial Guinea, Kazakhstan, and Iraq.

Cross referencing the DOJ information and the data on FCPA Tracker means up to 16 companies that were clients of Unaoil (and allegedly part of the bribery conspiracy) still haven’t publicly disclosed their Unaoil relationship.

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A statement from Unaoil dated June 16, 2016 and published on FCPA Tracker said: “Unaoil has instructed its lawyers to commence legal action against Fairfax Media and its partners in relation to the malicious and damaging allegations negligently published by these media organizations and repeated by other media organizations globally.”

About a month later the SFO confirmed “a criminal investigation into the activities of Unaoil, its officers, its employees and its agents in connection with suspected offenses of bribery, corruption and money laundering.”

The SFO’s release said, “We have been approached by a number of sources who may have information relevant to this investigation.”

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