Frank's International N.V. (Frank's) is a global provider of highly engineered tubular services to the oil and gas industry. It is headquartered in the Netherlands and its stock is traded on the NYSE.
Frank’s disclosed in its June 13, 2016 8-K filing that the company was conducting an internal investigation of the operations of certain of its foreign subsidiaries in West Africa, which included possible violations of the FCPA.
In June 2016, Frank’s voluntarily reported the internal review to the SEC and the DOJ, and the company subsequently reported that it was cooperating with the agencies.
During its internal investigation, Frank's discovered certain historical transactions in countries that may have been subject to U.S. and international sanctions. The company disclosed these discoveries to the U.S. Department of Commerce's Bureau of Industry and Security, Office of Export Enforcement, and the U.S. Department of Treasury's Office of Foreign Assets Control. On April 20, 2018, the OEE issued a no action letter stating that it had closed its investigation without taking further action. The company received a similar letter from OFAC on April 23, 2018.
On October 1, 2021, Frank's merged with Expro Group Holdings International Limited, and the resulting company was renamed Expro Group Holdings N.V. ("Expro"). Beginning with the company's 10-Q filed on November 8, 2021, Expro continued disclosures about the Frank's investigation.
In its 10-Q filed on November 3, 2022, Expro disclosed that it was in discussions with the SEC to resolve its its investigation into the company, and Expro had accrued $8 million in anticipation of the settlement. Expro also disclosed that the DOJ had concluded its investigation and did not intend to pursue any further action, subject to the company and the SEC reaching a satisfactory settlement of civil claims.
On April 26, 2023, the SEC issued a cease and desist order against Frank's and ordered the company to pay just under $8 million in disgorgement, interest, and penalties.
