Archives: Oil & Gas

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Rare Due Process Reprieve for Company Penalized by OFAC for Violating Ukraine Sanctions

Following a ruling issued last week by a federal judge in Texas, ExxonMobil Corporation (“ExxonMobil”) will not have to pay a previously issued penalty for contracting with Russia’s state-owned PJSC Rosneft Oil Company (“Rosneft”), since it was not provided fair notice by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) that … Continue Reading

Oil and Gas Giant Total S.A. Pays Fourth Highest Penalty In FCPA Enforcement History

On May 29, 2013, Total S.A. (“Total”), the French oil and gas conglomerate, entered into a three-year deferred prosecution agreement (DPA) with the DOJ and a settlement agreement with the SEC to resolve past violations of the FCPA’s anti-bribery, books and records and internal controls provisions.  As part of the agreements, Total will pay $245.2 … Continue Reading

Has the DOJ’s Ship Sailed from Bonny Island?

With the last member of the infamous TSKJ joint-venture resolving FCPA charges this week, has the DOJ finally closed the door on its very lucrative Bonny Island investigation?  JGC, a Japanese company headquartered in Yokohama, Japan, resolved an FCPA enforcement action brought by the DOJ concerning JGC’s participation in the Bonny Island, Nigeria, bribery scheme.  … Continue Reading

Bonny Island Keeps on Giving (to the US Treasury that is)

On Friday, March 11, Jeffrey Tesler, who had challenged extradition from the UK to the US, relented in his fight and pleaded guilty to one count of conspiracy to violate the FCPA and one substantive violation of an FCPA antibribery provision.  In 2009, the DOJ initially charged Tesler in an 11 count indictment consisting of … Continue Reading
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