David E. Gore ("Gore"), was a director and President of Triton Energy Corporation ("Triton Energy") from 1988 until his resignation in August of 1992. Robert W. Puetz ("Puetz"), was Triton Energy's Vice President of Finance and Chief Financial Officer ("CFO") in 1982 and was Senior Vice President of Finance and CFO from August 1989 until his resignation in April 1993. William L. McClure ("McClure"), was a contract auditor with Triton Indonesia, Inc. ("Triton Indonesia") from February 1990 until April 1990. He became Commercial Manager of Triton Indonesia in April 1990 and served in that capacity until November 1990 when he left the country. Robert P. Murphy, Jr. ("Murphy"), was a certified public accountant ("CPA") and was Controller of Triton Indonesia from January 1989 until November 1990. Philip W. Keever ("Keever"), was the Commercial Manager of Triton Indonesia from December 1988 until December 1989; Vice President and General Manager from January 1990 until May 1990; and President and General Manager from May 1990 until December 1990. Richard L. McAdoo ("McAdoo"), was Vice President and General Manager of Triton Indonesia from September/October 1988 until his termination by Triton in December 1989.
According to the cease and desist order, during the years 1989 and 1990, McAdoo and Keever authorized numerous improper payments to Roland Siouffi, Triton Indonesia's business agent acting as an intermediary between Triton Indonesia and Indonesian government agencies, knowing that Siouffi would pass those payments to Indonesian government employees for the purpose of influencing their decisions affecting the business of Triton Indonesia. In addition, McClure and Murphy initialled documents authorizing payments to Indonesian officials and Windusari, a Siouffi company, that were falsely documented and recorded in its books and records.
On February 27, 1997, without admitting or denying the allegations, Gore, Puetz, McClure, and Murphy consented to the enty of an administrative cease and desist order enjoining Gore and Puetz from future violations of the anti-bribery and books and records provisions of the FCPA, and McClure and Murphy from future violations of the books and records provisions of the FCPA. No monetary sanctions were imposed.
In a related action, Triton Energy, McAdoo, and Keever consented to the entry of a final judgment that permanently enjoined them from future violations of the FCPA. Triton Energy was ordered to pay a $300,000 civil penalty, Keever was ordered to pay a $50,000 civil penalty, and McAdoo was ordered to pay a $35,000 civil penalty.
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