In a follow-on prosecution and end to a twisted investigation and enforcement path, SBM Offshore agreed to settle an FCPA enforcement matter for $238 million (including a $500,000 criminal fine and $13.2 million forfeiture). Under the agreement, SBM offshore entered into a three-year deferred prosecution agreement (DPA, copy here), and a US subsidiary entered a guilty plea to one count of FCPA conspiracy. The Justice...

To all the “nattering nabobs of negativity” concerning FCPA enforcement, the US Justice Department responded with a resounding message – not only is FCPA enforcement here to stay, but individual violators are on DOJ’s radar screen. In an FCPA enforcement week like no other, the Justice Department unveiled a total of seven charging documents (indictments or informations) for FCPA violations, five arising from the Rolls...