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 | Investigations Dataset

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

Investigations Dataset

 
Investigation into Shell Nigeria's Activities in Nigeria in Connection with the Settlement of Litigation in 2011 · Royal Dutch Shell plc

Information & Summary

Investigation into Shell Nigeria's Activities in Nigeria in Connection with the Settlement of Litigation in 2011

Related FCPA Matter:   Royal Dutch Shell's Involvement in Nigeria in 2011 Information

Information & Summary

Investigation Name:    Investigation into Shell Nigeria's Activities in Nigeria in Connection with the Settlement of Litigation in 2011

Trend:    None

Type of investigation:    SEC, DOJ

Other Agencies Investigating/Assisting with SEC/DOJ Investigation:   

  • Unspecified U.S. Authorities
  • Dutch Public Prosecutor's Office
  • Italian Public Prosecutor of Milan (Procura della Repubblica presso il Tribunale de Milano)
  • Nigerian Law Enforcement Agency

Whistleblower:    Unknown

Summary

Royal Dutch Shell plc ("Shell") is an oil and gas company headquartered in the Netherlands. Shell International Exploration and Production Inc. is a Delaware company with headquarters in Houston, Texas and is a wholly owned indirect subsidiary of Shell.

In 2010, Shell and its subsidiary Shell Nigeria Exploration and Production Company Ltd. ("SNEPCO") settled FCPA enforcement actions with the DOJ and SEC. The settlements arose in connection with the company's use of the freight-forwarding firm Panalpina in Nigeria. During this time, SNEPCO was invested in a Nigerian oil project called OPL 245, and in 2011, the company settled litigation pertaining to that oil project.

In its 20-F filed on March 10, 2016, Shell disclosed that various countries were investigating the investment into OPL 245 and the circumstances surrounding the 2011 settlement. Though Shell did not disclose at the time which countries had opened investigation, subsequent filings revealed that at least Nigeria, Italy, the Netherlands, and the DOJ and SEC in the United States had all opened investigations in connection with SNEPCO's involvement in OPL 245. Moreover, Shell's initial disclosure in 2016 seemed to indicate that the FCPA or other relevant anti-bribery and corruption legislation or anti-money laundering laws were at issue in the investigations. Thus, the Clearinghouse infers that U.S. authorities, which were later confirmed to include the DOJ and SEC, were investigating at least as early as the initial 2016 disclosure.

In its 20-F filed on March 12, 2020, Shell confirmed that the DOJ had been investigating the company and that the DOJ informed the company on October 2, 2019, that it was closing its inquiry into the company.

In its 20-F filed on March 11, 2021, Shell confirmed that the SEC had been investigating the company and that the SEC notified the company on April 22, 2020 that it had closed its inquiry into the company.

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