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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. Trafigura Beheer B.V. · Trafigura's Involvement in Brazil between 2003 and 2014

Case Information

United States of America v. Trafigura Beheer B.V.

Related FCPA Matter:   Trafigura's Involvement in Brazil between 2003 and 2014 Information

Case Information

Initiation Date:    12/14/2023  Information

Prosecuting Agency:    U.S. Department of Justice

Type of Action:    DOJ Criminal Proceeding

Docket or Case Number:    23-cr-20476

Court:    S.D. Florida

Name of Prosecuting Attorneys:   

  • Glenn S. Leon, Chief, Fraud Section, Criminal Division
  • Markenzy Lapointe, United States Attorney
  • Natalie R. Kanerva, Trial Attorney, Fraud Section, Criminal Division
  • Clayton P. Solomon, Trial Attorney, Fraud Section, Criminal Division
  • Derek J. Ettinger, Assistant Chief, Fraud Section, Criminal Division
  • Jonathan P. Robell, Assistant Chief, Fraud Section, Criminal Division
  • Eli S. Rubin, Assistant United States Attorney
  • Joshua Paster, Assistant United States Attorney

US Assisting Agencies:   

  • Federal Bureau of Investigation

Foreign Enforcement Action/Investigation:   

  • Brazilian Law Enforcement Agency (Foreign Enforcement Action)

Foreign Assistance:   

  • Brazilian Law Enforcement Agency (BR)
  • Swiss Law Enforcement Agency (CH)
  • Urugruyan Law Enforcement Agency (UY)

Origin of the Proceeding:    Unknown

Whistleblower:    Unknown

Case Status:    Resolved


Summary  Information

Trafigura Beheer B.V., a Dutch company headquartered in Switzerland, operated as one of the largest oil distributors and energy commodities trading groups in the world. Among its numerous subsidiaries and affiliated entities was its Singapore-based subsidiary Trafigura Pte. Ltd.

According to the documents in this case, between approximately 2003 and 2014, Trafigura conspired with others to pay bribes to officials at the Brazilian state-owned oil company Petroleo Brasileiro S.A. - Petrobras in order to obtain lucrative business with the company. Trafigura agreed with its co-conspirators to make bribe payments through intermediaries of up to 20 cents per barrel of oil products bought from or sold to Petrobras by Trafigura. These payments were concealed through the use of shell companies and offshore bank accounts. In all, Trafigura made approximately $19.7 million in bribes and profited by approximately $61 million from the scheme.

On December 13, 2023, the DOJ filed a single-count information in the Southern District of Florida against Trafigura alleging a conspiracy to violate the antibribery provisions of the FCPA. On March 28, 2024, Trafigura entered into a plea agreement with the DOJ. Under the terms of the settlement, Trafigura agreed to pay a criminal fine of $80,488,040, forfeiture of $46,510,257, and a mandatory assessment of $400. The DOJ agreed to credit up to $26,829,346 of the criminal fine against amounts Trafigura pays to resolve an investigation by law enforcement authorities in Brazil for related conduct. The DOJ noted that despite being initially slow to cooperate and remediate, Trafigura ultimately cooperated and remediated sufficiently to receive a ten percent reduction off the fifth percentile of the applicable sentencing guidelines fine range. Trafigura further agreed to self-report on the status of its enhanced anticorruption compliance for a term of three years.

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