Foreign Corrupt Practices Act: Enforcement Action Dataset

Initiation Date: 07/07/2010

Prosecuting Agency: U.S. Securities and Exchange Commission

Type of Action: SEC Federal Court Proceeding

Docket or Case Number: 10-cv-2414

Court: S.D. Texas

Name of Prosecuting Attorneys:

Mark A. Adler, SEC Headquarters
Antonia Chion, SEC Headquarters
Kara N. Brockmeyer, SEC Headquarters
Robert G. Wilson, SEC Headquarters
Stanley M. Cichinski, SEC Headquarters
Ansu N. Banerjee, SEC Headquarters

US Assisting Agencies:

U.S. Department of Justice
Federal Bureau of Investigation

Foreign Enforcement Action/Investigation: Unknown

Foreign Assistance:

Foreign Law Enforcement Agency ()

Origin of the Proceeding: Unknown

Whistleblower: Unknown

Case Status: Resolved

Summary

ENI S.p.A. ("ENI") was an Italian multinational oil and gas company headquartered in Rome.

ENI's former subsidiary Snamprogetti was part of a four-company joint venture called TSKJ, which was comprised of Technip of France, Snamprogetti Netherlands B.V. of the Netherlands, Kellogg Brown & Root of the United States, and JGC Corporation of Japan. Between 1995 and 2004, members of the joint venture devised and implemented a scheme to bribe Nigerian government officials to obtain contracts worth over $6 billion to build liquefied natural gas (LNG) production facilities on Bonny Island in Nigeria. The joint venture partners formed a "cultural committee" comprised of senior sales executives at each company to consider how to carry out the bribery scheme. To conceal the illicit payments, the joint venture entered into sham contracts with a shell company controlled by a U.K. solicitor (Jeffrey Tesler, who was given $132 million for the purpose of bribing high-level Nigerian officials) and a Japanese trading company (Marubeni, which was given $51 million for the purpose of bribing low-level Nigerian officials) as conduits for the bribes. Total payments to the two agents exceeded $180 million.

On July 7, 2010, without admitting or denying the SEC's allegations, Snamprogetti and ENI consented to the entry of a final judgment permanently enjoining them from violating the anti-bribery, books and records, and internal controls provisions of the FCPA.

Snamprogetti and ENI agreed to be jointly and severally liable for disgorgement of $125 million.

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| Enforcement Action Dataset

Enforcement Action Dataset

Case Information

Securities and Exchange Commission v. ENI, S.p.A., et al.

Case Information

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