Willbros Group Inc. (WGI) was a publicly-traded company that provides construction, engineering, and other services in the oil and gas industry, and Willbros International Inc. (WII) was the wholly-owned subsidiary through which it conducts international operations.
From late 2003 through March 2005, WGI and WII employees agreed to make corrupt payments totaling more than $6.3 million to Nigerian government officials to assist in obtaining and retaining a $387 million contract for work on a major engineering, procurement, and construction gas pipeline project known as the Eastern Gas Gathering System (EGGS). In exchange for the EGGS project, the conspirators corruptly paid, promised to pay and authorized payments to officials of the Nigerian National Petroleum Corporation (NNPC), the state-owned oil company in Nigeria; NNPC’s subsidiary, the National Petroleum Investment Management Services (NAPIMS); a senior official in the executive branch of the Nigerian federal government; officials of a multinational oil company serving as the operator of the EGGS joint venture; and the dominant Nigerian political party.
In a separate transaction, WGI and WII employees agreed to make corrupt payments totaling approximately $4,000,000 to many of the same Nigerian government officials to assist in obtaining and retaining a contract to conduct repair work on existing offshore platforms in fields along the Nigerian coast.
In yet another separate transaction, WGI and WII employees based in South America agreed to make approximately $300,000 in corrupt payments to Ecuadoran government officials of the state-owned oil company PetroEcuador and its subsidiary, PetroComercial, to assist in obtaining the Santo Domingo project, which involved the rehabilitation of approximately sixteen kilometers of a gas pipeline in Ecuador, running from Santo Domingo to El Beaterio.
Once the corrupt actions came to light, WGI and WII conducted a thorough internal investigation and shared its results with the SEC and DOJ. WGI and WII entered into a Deferred Prosecution Agreement with the DOJ.
WGI and WII agreed, jointly and severally, to pay a criminal penalty of $22,000,000 payable in four installments: $10,000,000 paid within 10 days of executing the deferred prosecution agreement; two $4,000,000 installments on or before the first and second anniversaries of the initial payment date; and a fourth payment of $4,000,000 after the third anniversary of the initial payment, but before the end of the deferred prosecution agreement, which would run for three years and seven days from May 14, 2008.
In addition, Willbros Group, Inc. and Willbros International, Inc. represented that they had implemented and would continue to implement a compliance and ethics program and a review of existing controls, policies and procedures, would continue to cooperate with the government investigation, and would engage an independent corporate monitor for a term of 3 years.
