October 2009

Oil and Gas Industry Supplier Completes FCPA Internal Investigation and Remediation

A private U.S. supplier to the oil and gas industry engaged us to lead a FCPA investigation into direct and indirect sales practices in China and Indonesia. The result was termination of third-party relationships, a company executive’s resignation from the board of a joint venture, discipline of culpable employees, and enhancement of compliance program and oversight. We recommended no voluntary disclosure.

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