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 | Enforcement Action Dataset

Stanford Foreign Corrupt Practices Act Clearinghouse a Collaboration with Sullivan & Cromwell LLP

Enforcement Action Dataset

 
In the Matter of Total, S.A. · Total's Involvement in Iran from 1995 to 2005

Case Information

In the Matter of Total, S.A.

Related FCPA Matter:   Total's Involvement in Iran from 1995 to 2005 Information

Case Information

Initiation Date:    05/29/2013  Information

Prosecuting Agency:    U.S. Securities and Exchange Commission

Type of Action:    SEC Administrative Proceeding

Docket or Case Number:    3-15338

Name of Prosecuting Attorneys:    Unknown

US Assisting Agencies:   

  • Department of Justice - Criminal Division's Office of International Affairs

Foreign Enforcement Action/Investigation:    Unknown

Foreign Assistance:    Unknown

Origin of the Proceeding:    Foreign investigation

Whistleblower:    Unknown

Case Status:    Resolved


Summary  Information

Total, S.A. ("Total"), was a French corporation headquartered in Nanterre, France. At all relevant times, it was engaged in the business of exploring for and developing oil and gas resources around the world. Total owned a number of subsidiaries that conducted business in the United States. Total's American Depositary Shares were registered with the SEC and traded on the New York Stock Exchange.

From around May 1995 until about November 29, 2004, Total and its co-conspirators, including Intermediary One and Intermediary Two, participated in a scheme to pay approximately $60 million in unlawful payments to intermediaries designated by an Iranian official, who was the Chairman of an Iranian engineering company that was more than 90% owned by the Government of Iran as well as the head of an Iranian organization concerned with fuel consumption, which was a wholly owned subsidiary of National Iranian Oil Company ("Iranian Official"). The purpose of the payments was to induce the Iranian Official to use his influence to assist Total in obtaining and retaining over $1 billion of business related to the Sirri A and E and South Pars oil and gas field development projects. The award of the development interests in Sirri A and E and the South Pars Projects, combined, netted Total approximately $150 million in profits.

On May 29, 2013, the SEC instituted an administrative proceeding against Total ordering it to cease and desist violating the anti-bribery, books & records, and internal controls provisions of the FCPA. Under the terms of the proceeding, Total was further required to disgorge $153 million and to hire for a term of three years an independent compliance consultant to review and report on Total's anti-corruption compliance policies and procedures.

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