Technip Leniency Agreement
“This case shows that the FBI will continue to work tirelessly to hold those who treat corruption and corruption to account as a common business practice,” Acting Special Agent Charge Dayoub said. “Today`s agreement is the culmination of the hard work of the FBI, the Department of Justice and our international partners.” SBM Offshore has confirmed that it has secured the end of its three-year agreement with the Ministry of Justice for FCPA violations, but the oil and gas services company is now facing a new corruption investigation by Swiss law enforcement agencies. In addition, TechnipFMC has entered into an agreement in principle with SEC staff, subject to final approval by the SEC, the oilfield service provider said. As noted below, the resolutions highlight the risks associated with succession liability. TFMC inherited significant FCPA liabilities as part of its 2017 merger. In 2010, Technip S.A., whose American Depository Shares was traded on the New York Stock Exchange between August 2001 and November 2007, entered into a two-year agreement and a $240 million transaction with DOJ to participate in a bribery plan for Nigerian officials to secure engineering, procurement and construction contracts.  Some of the offences committed by the company in Brazil and Iraq took place during the 2010 prison agreement, while Technip S.A. was under the control of a Corporate Compliance Monitor.  TFMC entered into a deferred prosecution agreement with the department in connection with a criminal investigation filed today in the Eastern District of New York, charging the company with two counts of conspiracy to violate the corrupt practices provisions of the Foreign Corrupt Practices Act (FCPA).
In addition, Technip USA pleaded guilty and was convicted of a charge that charged it with conspiracy to violate fcPA`s anti-bribery provisions. Under its agreement with the ministry, TechnipFMC will pay a total fine of more than $296 million, including a $500,000 fine paid by Technip USA. As part of the adjourned prosecution agreement, TechnipFMC committed to strict internal controls and to cooperate fully with the department`s ongoing investigations. In addition, Technip has entered into an agreement in principle with U.S. SEC staff, which has yet to be definitively approved. TechnipFMC has entered into a three-year agreement with the Ministry of Justice for conspiracy to violate the Foreign Corrupt Practices Act (FCPA) in connection with conduct in Brazil and unaoil. Technip, a subsidiary of Technip USA Inc., pleaded guilty to one count of conspiracy to violate the FCPA in connection with the company`s conduct in Brazil. The company is also required to provide reports on its anti-corruption program for three years. In Brazil, TechnipFMC subsidiaries have Technip Brasil – Engenharia, Instalaes E Apoio Marétimo Ltda. and Flexibris Tubos Flexéveis Ltda. more than a decade ago, leniency agreements were reached with the MPF and the CGU/AGU on behaviour in Brazil.