STATOIL, ASA ("Statoil") was a public company headquartered in Stavanger, Norway. Statoil explored, developed, produced and sold oil and natural gas resources around the globe.
Statoil sought to expand its business internationally and focused specifically on Iran as a country in which to secure oil and gas development rights. At the time, Iran was awarding contracts for the development of the South Pars field, one of the world’s largest natural gas fields. In 2001, Statoil developed contacts with and began negotiating with an Iranian government official who could influence the award of oil and gas contracts in Iran. Statoil then entered into a "consulting contract" with an offshore intermediary company. The purpose of that "consulting contract" – which called for the payment of more than $15 million over 11 years – was to induce the Iranian official to use his influence to help Statoil obtain a contract to develop portions of the South Pars field, and to open doors to future Iranian oil and gas projects. Two bribe payments of $200,000 and $5,000,000 were made by wire transfer, and Statoil was awarded a South Pars development contract that was expected to yield millions of dollars in profit.
On October 13, 2006, without admitting or denying the SEC's allegations, Statoil consented to the entry of an administrative cease and desist order enjoining the company from future violation of the FCPA's anti-bribery, books and records, and internal control provisions. Statoil will be required to pay $10,500,000 in disgorgement.
In a related action, Statoil entered into a three-year deferred prosecution agreement with the DOJ. Under the DPA, Statoil agreed to pay a criminal penalty of $10,500,000. Statoil received credit for paying NOK 20,000,000 ($3,000,000) to the National Authority for Investigation and Prosecution of Economic and Environmental Crime ("0kokrim"), and will only have to pay criminal penalty of $7,500,000.
In October 2004, Statoil settled its case with 0kokrim, agreeing to pay a penalty of NOK 20,000,000 ($3,000,000). The Senior Executive also agreed to pay a penalty of $30,000, charging them with violating Norway's trading-in-influence statute. Statoil and the Senior Executive agreed to pay the penalties without admitting or denying the violations.
