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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 Tenaris S.A. · Tenaris' Involvement in Brazil between 2008 and 2013

Case Information

In the Matter of Tenaris S.A.

Related FCPA Matter:   Tenaris' Involvement in Brazil between 2008 and 2013 Information

Case Information

Initiation Date:    06/02/2022  Information

Prosecuting Agency:    U.S. Securities and Exchange Commission

Type of Action:    SEC Administrative Proceeding

Docket or Case Number:    3-20875

Name of Prosecuting Attorneys:   

  • Jennifer Moore, SEC Headquarters
  • Steven A. Susswein, SEC Headquarters
  • Maria Boodoo, SEC Headquarters
  • Tracy L. Price, SEC Headquarters

US Assisting Agencies:    Unknown

Foreign Enforcement Action/Investigation:    Unknown

Foreign Assistance:   

  • Brazilian Federal Prosecution Office (Ministerio Publico Federal) (BR)
  • Italian Public Prosecutor of Milan (Procura della Repubblica presso il Tribunale de Milano) (IT)
  • Panamanian Superintendencia del Mercado de Valores (SMV) (PA)

Origin of the Proceeding:    Unknown

Whistleblower:    Unknown

Case Status:    Resolved


Summary  Information

Tenaris S.A., headquartered in Luxembourg, was a global manufacturer and supplier of steel pipe products and related services. Tenaris' ADRs traded on the New York Stock Exchange.

According to the documents in this case, between 2008 and 2013, Tenaris' Brazilian subsidiary Confab Industrial S.A. paid approximately $10.4 million in bribes through its local agent to a high-ranking manager at Petroleo Brasileiro S.A. ("Petrobras"), Brazil's state-owned oil company, in order to rig the bidding process in favor of Confab. In all, Confab obtained more than $1.0 billion in contracts from Petrobras.

In a settled administrative proceeding initiated on June 2, 2022, the SEC ordered Tenaris to cease and desist violations of the antibribery, books and records, and internal controls provisions of the FCPA. Under the terms of the settlement, Tenaris agreed to pay a civil fine of $25,000,000 and to disgorge $42,842,497 plus prejudgment interest of $10,257,841. Tenaris also agreed to self-report to the SEC on the status of its enhanced anticorruption compliance policies and procedures for a term of two years.

Tenaris previously settled FCPA-related enforcement actions with the DOJ and SEC in 2011 for misconduct in Uzbekistan.

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