Red Notice Newsletter - December 2017

ANTICORRUPTION DEVELOPMENTS –

Keppel Offshore Reaches Deal with DOJ and Guilty Plea by Counsel Unsealed –

On December 22, 2017, Keppel Offshore & Marine Ltd. (KOM), a Singapore based company that operates shipyards and repairs and upgrades shipping vessels, and its wholly owned subsidiary, Keppel Offshore & Marine USA Inc. (KOM USA), agreed to pay more than $422 million to resolve the Department of Justice's (DOJ) investigation of alleged violations of the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA) as well as parallel investigations by Brazilian and Singaporean enforcement agencies. KOM entered into a non-prosecution agreement with the DOJ while KOM USA and a former senior member of KOM’s legal department pleaded guilty in connection with the resolution.

Specifically, the DOJ alleges, beginning in at least 2001 and continuing until at least 2014, KOM paid approximately $55 million in bribes to officials at the Brazilian state-owned oil company Petrobras and to the then governing political party in Brazil. The DOJ further alleges that KOM concealed the payments by paying outsized commissions to an intermediary, under the guise of legitimate consulting agreements, which the in house attorney is alleged to have drafted.

Please see full Newsletter below for more information.

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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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