Foreign Corrupt Practices Act: Enforcement Action Dataset

Initiation Date: 07/23/2018

Prosecuting Agency: U.S. Department of Justice

Type of Action: DOJ Criminal Proceeding

Docket or Case Number: 18-cr-00415

Court: S.D. Texas

Name of Prosecuting Attorneys:

Ryan K. Patrick, United States Attorney
Suzanne Elmilady, Assistant United States Attorney
Sandra L. Moser, Acting Chief, Fraud Section, Criminal Division
Dennis R. Kihm, Trial Attorney, Fraud Section, Criminal Division
Gerald M. Moody, Jr., Trial Attorney, Fraud Section, Criminal Division
Jonathan P. Robell, Trial Attorney, Fraud Section, Criminal Division
Gwendolyn A. Stamper, Trial Attorney, Fraud Section, Criminal Division

US Assisting Agencies:

U.S. Securities and Exchange Commission
Federal Bureau of Investigation
Internal Revenue Service
U.S. Postal Inspection Service

Foreign Enforcement Action/Investigation: Unknown

Foreign Assistance:

Canadian Law Enforcement Agency (CA)
French Law Enforcement Agency (FR)
Swiss Law Enforcement Agency (CH)
U.K. Law Enforcement Agency (GB)
Italian Law Enforcement Agency (IT)
Guernsey Law Enforcement Agency (GB)
Australian Law Enforcement Agency (AU)
Dutch Law Enforcement Agency (NL)
Monaco Law Enforcement Agency (MC)
Portuguese Law Enforcement Agency (PT)
Eurojust: European Union Agency for Criminal Justice Cooperation (EU)

Origin of the Proceeding: Unknown

Whistleblower: Unknown

Case Status: Ongoing

Summary

Unaoil S.A.M. was a Monaco-based group of affiliated companies that provided services for various multinational companies operating in the energy sector. Unaoil maintained business operations through its various subsidiaries and affiliates in multiple countries, including in Algeria, Angola, Azerbaijan, Iraq, Kazakhstan, Libya, the United Arab Emirates, and elsewhere, and at one point, the company directly and indirectly employed or retained over 1,400 employees and contractors.

Steven Hugh Hunter joined Unaoil in 2009 as the company's Business Development Director.

According to the documents in this case, between 2009 and 2015, Hunter conspired with others to make bribe payments to officials at Libya's state-owned oil company, The National Oil Corporation. These bribes were made to obtain business for Unaoil and its client companies.

On July 23, 2018, the DOJ filed a sealed single count Information in the Southern District of Texas against Hunter alleging conspiracy to violate the anti-bribery provisions of the FCPA. According to a DOJ press release, Hunter pled guilty on August 2, 2018. However, any plea agreement remains under seal, so its details are unknown. Hunter is scheduled to be sentenced on December 1, 2025.

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| Enforcement Action Dataset

Enforcement Action Dataset

Case Information

United States of America v. Steven Hugh Hunter

Case Information

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