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 | Enforcement Action Dataset

Stanford Foreign Corrupt Practices Act Clearinghouse a Collaboration with Sullivan & Cromwell LLP

Enforcement Action Dataset

 
United States of America v. Luiz Eduardo Andrade · Sargeant Marine's Involvement in Brazil, Ecuador, and Venezuela between 2010 and 2018

Case Information

United States of America v. Luiz Eduardo Andrade

Related FCPA Matter:   Sargeant Marine's Involvement in Brazil, Ecuador, and Venezuela between 2010 and 2018 Information

Case Information

Initiation Date:    09/22/2017  Information

Prosecuting Agency:    U.S. Department of Justice

Type of Action:    DOJ Criminal Proceeding

Docket or Case Number:    17-cr-00497

Court:    E.D. New York

Name of Prosecuting Attorneys:   

  • Bridget M. Rohde, Acting U.S. Attorney
  • Sandra L. Moser, Acting Chief, Fraud Section, Criminal Division
  • Mark E. Bini, Assistant United States Attorney
  • Whitman G.S. Knapp, Assistant United States Attorney

US Assisting Agencies:   

  • Federal Bureau of Investigation

Foreign Enforcement Action/Investigation:    Unknown

Foreign Assistance:   

  • Brazilian Law Enforcement Agency (BR)

Origin of the Proceeding:    Unknown

Whistleblower:    Unknown

Case Status:    Resolved


Summary  Information

Sargeant Marine Inc. was a large asphalt company incorporated and based in Boca Raton, Florida.

Luiz Eduardo Andrade, a Brazilian national, worked as an agent for Sargeant Marine in Brazil from approximately the end of 2009 through at least early 2016. Andrade's responsibilities included seeking contracts with the Brazilian state-owned oil company, Petroleo Brasileiro S.A. - Petrobras, for Sargeant Marine and its related companies.

According to the documents in this case, between 2010 and 2017, Andrade conspired to pay bribes to several Brazilian officials on behalf of Sargeant Marine and associated companies so that they could obtain and retain business with Petrobras. Andrade facilitated bribe payments to at least two officials at Petrobras and two Brazilian politicians by using, among other things, a U.S. bank account, a Swiss bank account, and shell companies incorporated in the Marshall Islands. In all, Sargeant Marine and other related asphalt companies obtained contracts with Petrobras with a value in excess of approximately $165 million.

On September 22, 2017, the DOJ filed a single count Information in the Eastern District of New York against Andrade alleging a conspiracy to violate the anti-bribery provisions of the FCPA. According to the docket, Andrade pled guilty on the same day, but the details of any plea agreement are currently unknown. On May 17, 2024, the court ordered Andrade to forfeit $140,000, and on May 23, the court sentenced him to 1 year of probation and ordered him to pay a mandatory assessment of $100.

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