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 | Investigations Dataset

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

Investigations Dataset

 
Investigation into Noble/Paragon's Activities in Brazil re: Petrobras · Noble Corporation

Information & Summary

Investigation into Noble/Paragon's Activities in Brazil re: Petrobras

Related FCPA Matter:   Noble Corp. and Paragon Offshore's Involvement in Brazil Information

Information & Summary

Investigation Name:    Investigation into Noble/Paragon's Activities in Brazil re: Petrobras

Trend:    Petrobras

Type of investigation:    Internal, SEC, DOJ

Other Agencies Investigating/Assisting with SEC/DOJ Investigation:   

  • Brazilian Federal Prosecution Office (Ministerio Publico Federal)

Whistleblower:    Unknown

Summary

Noble Corporation ("Noble") is a leading offshore drilling contractor for the oil and gas industry. In 1996, Noble moved from the NASDAQ to the NYSE and began trading under the symbol NE. Noble performs, through its subsidiaries, contract drilling services with a fleet of 69 offshore drilling units worldwide.

According to its SEC filings, a subsidiary of Noble used a commercial agent in Brazil in connection with Petróleo Brasileiro S.A. (Petrobras) drilling contracts. The agent pleaded guilty in Brazil in connection with the award by Petrobras of a drilling contract to one of Noble’s competitors as part of a wider investigation of Petrobras’ business practices. The agent represented a number of different companies in Brazil over many years, including several offshore drilling contractors. Following the news reports relating to the agent’s involvement in the Brazil investigation in connection with his activities with other companies, Noble began conducting an independent review of its relationship with the agent and with Petrobras. Noble was contacted by the SEC in connection with an earlier disclosure, and the company subsequently contacted the DOJ to advise them of the internal review.

This investigation is related to the similar investigation of Paragon Offshore plc, which was spun off from Noble in 2014.

In its 10-K filed on February 22, 2019, Noble announced that both the SEC and DOJ had contacted the company in December 2018 to inform it that the investigations into the company had been closed.

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