Frank’s International N.V. ("Frank's") was a global provider of engineered tubular services, tubular fabrication, and specialty well construction and well intervention solutions to the oil and gas industry, incorporated and headquartered in the Netherlands. From its August 9, 2013, initial public offering, until October 1, 2021, Frank’s securities were registered with the SEC and traded on the New York Stock Exchange. In October 2021, Frank's merged with Expro Group Holdings International Limited, and the resulting company was renamed Expro Group Holdings N.V.
According to the documents in this case, between January 2008 and October 2014, Frank’s paid commissions to a sales agent in Angola despite a high probability that the agent would use the commissions to bribe Angolan government officials on behalf of Frank’s. During the course of his representation, the Angolan agent received approximately $5.5 million from Frank’s Angolan subsidiary, a portion of which was paid to a senior official at the Angolan state-owned oil company Sociedade Nacional de Combustiveis de Angola, E.P. (“Sonangol”). Frank’s received at least $4,176,858 in post-IPO net profits from its contracts with oil companies where Sonangol was the ultimate customer and for which Sonangol officials possessed decision-making authority.
In a settled administrative proceeding initiated on April 26, 2023, the SEC ordered Frank's to cease and desist violations of the antibribery, books & records, and internal controls provisions of the FCPA and ordered the company to pay disgorgement of $4,176,858 plus prejudgment interest of $821,863 and a civil money penalty of $3,000,000. The SEC noted Frank's self-disclosure, cooperation, and remediation.