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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 TechnipFMC plc. · Keppel Offshore and TechnipFMC's Involvement in Brazil between 2001 and 2014

Case Information

In the Matter of TechnipFMC plc.

Related FCPA Matter:   Keppel Offshore and TechnipFMC's Involvement in Brazil between 2001 and 2014 Information

Case Information

Initiation Date:    09/23/2019  Information

Prosecuting Agency:    U.S. Securities and Exchange Commission

Type of Action:    SEC Administrative Proceeding

Docket or Case Number:    3-19493

Name of Prosecuting Attorneys:   

  • Akita N. Adkins, SEC Headquarters
  • Maria Boodoo, SEC Headquarters
  • David B. Reece, SEC Fort Worth Regional Office
  • Tracy L. Price, SEC Headquarters

US Assisting Agencies:   

  • U.S. Department of Justice

Foreign Enforcement Action/Investigation:    Unknown

Foreign Assistance:   

  • U.K. Serious Fraud Office (GB)
  • Monaco Law Enforcement Agency (MC)

Origin of the Proceeding:    Unknown

Whistleblower:    Unknown

Case Status:    Resolved


Summary  Information

TechnipFMC plc ("TechnipFMC") was a global provider of oil and gas technology and services. TechnipFMC was the product of a 2017 merger between Technip S.A. ("Technip") and FMC Technologies, Inc. ("FMC Technologies").

Prior to the merger, Technip was a global oil and gas technology and services company that was headquartered in France. Technip operated through a variety of foreign subsidiaries, including its wholly-owned American subsidiary Technip USA Inc. ("Technip USA). Between at least August 2001 and November 2007, Technip's shares were registered with the SEC and traded on the New York Stock Exchange. FMC Technologies was an oil field services and equipment company based in Texas. FMC Technologies' stock was registered with the SEC and traded on the New York Stock Exchange.

According to the documents in this case, between 2008 and 2013, FMC Technologies made over $794,000 in payments to a Monaco-based third party consultant (though not identified in this case, the consultant was identified in FMC Technologies' SEC filings as Unaoil), which used at least some of those funds to pay bribes to Iraqi government officials to procure business with Iraqi state-owned oil companies. The payments were subsequently not accurately reflected in FMC Technologies’ books and records.

In a settled administrative proceeding initiated on September 23, 2019, the SEC ordered TechnipFMC to cease and desist violations of the anti-bribery, books and records, and internal controls provisions of the FCPA. Under the terms of the settlement, the SEC ordered TechnipFMC to pay disgorgement of $4,327,194 plus prejudgment interest of $734,712, and the company agreed to self-report on the implementation of its enhanced anti-corruption compliance policies and procedures for a term of three years. The SEC noted TechnipFMC's cooperation and remediation.

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