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Today, in what the FCPA Blog called "making FCPA history", the Department of
Justice (DOJ) and the Securities and Exchange Commission (SEC) announced the
agreement by the Global logistics firm Panalpina and the energy companies
Shell, Transocean, Tidewater, Noble and Pride International to resolve various
outstanding FCPA charges. The total amount of penalties is $156.565 million in
criminal fines and about $73.9 million in civil disgorgement, interest and
SETTLEMENT BOX SCORE
DPA or NPA
In addition to the total amount going to the US Treasury
of approximately $229.5, the most interesting item noted is that none of the
parties was required to have a corporate monitor as a part of its settlement.
In future posts we will review the specific Deferred Prosecution Agreements (or
Non-Prosecution Agreement) to see if we might glean some of the DOJ's concepts
of current FCPA compliance best practices.
Download the DPA for Panalpina here, Shell here,
Tidewater here, Pride here, Transocean here,
and the NPA for Noble here.
Visit the FCPA Compliance
and Ethics Blog, hosted by
Thomas Fox, for more commentary on FCPA compliance, indemnities and other forms
of risk management for a worldwide energy practice, tax issues faced by
multi-national US companies, insurance coverage issues and protection of trade
This publication contains general information
only and is based on the experiences and research of the author. The author is
not, by means of this publication, rendering business, legal advice, or other
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© Thomas R. Fox, 2010