Rolls-Royce plc was a U.K. publicly traded company with major business operations in the civil aerospace, defense, marine, and energy sectors worldwide.
Rolls-Royce Energy Systems, Inc. ("RRESI"), headquartered in Mount Vernon, Ohio, produced and supplied pipeline and barrel centrifugal compressors and power turbines and aftermarket services for oil and gas and power generation projects worldwide, including in Angola, Azerbaijan, Brazil, Indonesia, Iraq, Kazakhstan, Nigeria, Russia, and Thailand.
Keith Barnett worked in a sales capacity for RRESI from about 2000 to 2012. During that time, Barnett worked as an Oil & Gas Market Manager for the Asia/Pacific region, an Oil & Gas Sales Director for North America, Africa, and Europe, and finally as the Regional Director for the Asia/Pacific region.
From around 2001 through 2012, Barnett and others conspired to pay bribes to a high-ranking Kazakh governmental official to retain business for Rolls-Royce. The Kazakh official worked at KazMunayGas, a Kazakh state-owned entity that had authority over Asia Gas Pipeline, LLC, a state-owned joint venture between the Kazakh and Chinese governments created to build and connect a gas pipeline between the two countries. In his capacity at the Kazakh entity, the Kazakh offcial could exert influence of the joint venture's purchasing decisions. The payments to the Kazakh official were made through an intermediary entity controlled by one of the co-conspirators, and in November 2009, RRESI won a contract worth approximately $145 million to supply 11 gas turbine units to the joint venture for approximately $145 million. In all, the conspirators paid the foreign official at least $1,947,023 in a series of payments.
On December 20, 2016, the DOJ filed a single count Information in the Southern District of Ohio against Barnett alleging conspiracy to violate the anti-bribery provisions of the FCPA. On the same date, Barnett entered into a plea agreement with the government. However, the plea agreement remains under seal, so the details of the agreement are not known. On July 30, 2019, the court sentenced Barnett to 3 years probation and ordered him to pay a fine of $250,000 plus a mandatory assessment of $100. The court further ordered that half of the fine would be paid to the U.S. Postal Service.
