Following last year's prosecution of Halliburton/KBR for Foreign Corrupt Practices Act violations related to the Bonny Island natural gas project, over the past few weeks, the U.S. Department of Justice and the U.S. Securities & Exchange Commission charged two more partners of the TSKJ consortium, Technip, a French company and Snamprogetti Netherlands, as well as Snamprogetti' parent, the Italian oil company Eni S.p.A. The pleadings provide revealing insights into how the U.S. authorities view the jurisdictional scope of the FCPA over non-U.S. companies and how they intend to force such companies to implement the U.S. government’s view of what constitutes adequate and effective internal anti-corruption controls, thereby seeking to establish an international standard based on U.S. experience under the FCPA.
View full memo, "The Other FCPA Shoe Drops: Expanded Jurisdiction over Non-U.S. Companies, Foreign Monitors, and Extending Compliance Controls to Non-U.S. Companies"