SBM Offshore N.V. was a publicly traded Dutch company with offices in Amsterdam, Monaco, Switzerland, and Houston, Texas. SBM Offshore specialized in designing, constructing, and providing offshore oil and gas drilling equipment. The company maintained several wholly-owned subsidiaries based in Houston, including SBM Offshore USA Inc.
Anthony Mace was a U.K. citizen who served as the Chief Executive Officer for SBM Offshore from April 2008 through December 2011. During his tenure as CEO, Mace worked out of the company's Monaco or Amsterdam offices. From 2000 through 2011, Mace was also an executive and board member for one of SBM Offshore's Houston-based subsidiaries.
According to the Information, beginning in around 1996, before Mace became CEO, SBM Offshore, its Houston-based subsidiary, and various executives, employees, and sales agents entered into an agreement to pay bribes to foreign officials, including officials at Petrobras, Sonangol, and GEPetrol, the national oil companies of Brazil, Angola, and Equatorial Guinea, respectively, in order to obtain and retain business for SBM Offshore. These bribes were primarily paid through two intermediaries and shell companies controlled by the intermediaries. The bribes continued through 2012.
On October 19, 2017, the DOJ filed a single count Information in the Southern District of Texas against Mace alleging conspiracy to violate the anti-bribery provisions of the FCPA. On November 9, 2017, Mace entered into a plea agreement with the government. On September 28, 2018, the court sentenced Mace to 3 years in prison to be followed by 1 year of supervised release and ordered him to pay a fine of $150,000 plus a mandatory assessment of $100.
In a related proceeding, on October 6, 2017, the DOJ filed a single count Information in the Southern District of Texas against Robert Zubiate alleging conspiracy to violate the anti-bribery provisions of the FCPA. According to the DOJ press release announcing the enforcement action, Zubiate pled guilty on November 6, 2017. On September 28, 2018, the court sentenced Zubiate to 30 months in prison to be followed by 3 years of supervised release and ordered him to pay a fine of $50,000 plus a mandatory assessment of $100.
