Red Notice Newsletter - October 2019

ANTICORRUPTION DEVELOPMENTS -

Former Unaoil Executives Plead Guilty to FCPA Charges -

On October 30, 2019, the Department of Justice (DOJ) announced that three former executives from Unaoil, a Monaco-based oil services company, had previously pleaded guilty to participating in a scheme to make improper payments to government officials in violation of the Foreign Corrupt Practices Act (FCPA). Former CEO Cyrus Ahsani and former COO Saman Ahsani pleaded guilty on March 25, 2019, to one count of conspiracy to violate the FCPA, while former business development director Steven Hunter pleaded guilty on August 2, 2018, to the same charge. The Ahsanis were alleged to have engaged in a conspiracy from 1999 to 2016 to secure oil and gas contracts by funneling millions of dollars in illicit payments to government officials in countries including Algeria, Angola, Azerbaijan, the Democratic Republic of Congo, Iran, Iraq, Kazakhstan, Libya and Syria. Hunter was said to have participated in the scheme from 2009 to 2015 with respect to officials in Libya. As previously covered by Red Notice, Unaoil is also under investigation by the UK Serious Fraud Office.

The Ahsanis are scheduled for sentencing on April 20, 2020, while Hunter’s sentencing is scheduled for March 13, 2020. Their cases are pending in federal court in the Southern District of Texas.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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