Debevoise & Plimpton

FCPA update: December 2013 — Vol. 5, No. 5

By Sean Hecker, Andrew M Levine and Philip Rohlik

On 26 November, the Securities and Exchange Commission and the Department of Justice announced settlements with Weatherford International and its subsidiary, Weatherford Services, involving a wide variety of FCPA violations in Africa, the Middle East and Europe occurring from 2000 to 2011. The settlements — involving a financial resolution of $152.5m (£93m) for FCPA violations, the imposition of a monitor for 18 months and an additional 18 months’ self-reporting obligation — were part of a $252m global settlement between Weatherford and several of its subsidiaries and the US government for violations of the FCPA and US sanctions laws prohibiting certain transactions with Cuba, Iran, Syria and Sudan.

Weatherford is a Swiss oil equipment and services corporation. Prior to 2009, Weatherford’s headquarters was in Houston, Texas, where it still has significant operations. WSL is a wholly owned subsidiary of Weatherford, incorporated in Bermuda with operations in, among other places, Angola and Congo. As part of the recent resolution, Weatherford entered into a three-year deferred prosecution agreement with the US, supported by an information detailing criminal violations of the FCPA’s internal controls requirements. Weatherford also settled a civil complaint brought by the Securities and Exchange Commission. Separately, WSL entered a guilty plea for violating the FCPA’s anti-bribery provisions, as detailed in a criminal information…

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