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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 Halliburton Company and Jeannot Lorenz · Halliburton's Involvement in Angola and Iraq

Case Information

In the Matter of Halliburton Company and Jeannot Lorenz

Related FCPA Matter:   Halliburton's Involvement in Angola and Iraq Information

Case Information

Initiation Date:    07/27/2017  Information

Prosecuting Agency:    U.S. Securities and Exchange Commission

Type of Action:    SEC Administrative Proceeding

Docket or Case Number:    3-18080

Name of Prosecuting Attorneys:    Unknown

US Assisting Agencies:   

  • U.S. Department of Justice
  • Federal Bureau of Investigation

Foreign Enforcement Action/Investigation:    Unknown

Foreign Assistance:    Unknown

Origin of the Proceeding:    Unknown

Whistleblower:    Unknown

Case Status:    Resolved


Summary  Information

Halliburton Company was an oilfield services corporation, headquartered in Houston, Texas. The company's stock was registered with the SEC and traded on the New York Stock Exchange. Halliburton previously entered into a settlement with the SEC in February 2009 in connection with a bribery scheme perpetrated by its former subsidiary KBR, Inc.

Jeannot C. Lorenz was a French citizen and permanent resident of the U.S. who, at the time of the misconduct, was a Vice President at Halliburton and who variously served as the country manager for Angola and Brazil.

In early 2008, officials at Angola's state-owned oil company, Sonangol, informed Halliburton that Sonangol was considering vetoing further subcontract work for Halliburton in Angola because the company had insufficient local content and was thus not compliant with Angola's local content rules. In response, Halliburton tasked Lorenz with finding local content in Angola that would satisfy Sonangol. In April 2009 when a new round of contracts for Sonangol projects were coming up for bid, Lorenz proposed that Halliburton outsource approximately $15 million of services to a local Angolan company to fulfill its local content obligations. This local Angolan company was owned by a former Halliburton employee who was a friend and neighbor of the Sonangol official who had the authority to veto or reduce the Haliburton subcontracts. Because of the connection to the Sonangol official and because the contracts provided inaccurate scopes of work, the contracts violated Halliburton's internal accounting controls, and Halliburton's books and records subsequently included inaccurate information.

In an administrative proceeding on July 27, 2017, the SEC issued a settled Cease and Desist Order against Halliburton and Lorenz alleging violations of the books & records and internal controls provisions of the FCPA. Without admitting or denying the allegations within, both Halliburton and Lorenz agreed to be enjoined from future violations of the FCPA. Lorenze agreed to pay a civil fine of $75,000. Halliburton agreed to disgorge $14 million in ill-gotten profits plus $1.2 million in prejudgment interest and to pay a civil fine of $14 million. Halliburton also agreed to hire an independent compliance monitor for a term of 18 months.

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