DoJ Fine Technip $296mn FCPA

• TechnipFMC and subsidiary Technip USA agreed to pay over $296mn in FCPA fine.
• Company is a global provider of oil and gas services, and product of 2017 merger
  between two predecessor companies, Technip S.A. and FMC Technologies (FMC).
• Charged 2 separate bribery schemes: Technip Brazil bribes, and FMC Iraq bribes.
• Follows 2010 $240mn FCPA penalty paid by Technip, re Nigeria bribery

Brazil Scheme

• From about 2003-13, Technip conspired with Keppel Offshore & Marine (KOM) of Singapore, and their prior consultant, to give him $69mn commission payments.
• Consultant passed along part of $69mn, as bribes to Brazil government officials.
• Brazilian officials were employees with Brazil state-owned oil company, Petrobras.
• Bribes paid to secure improper advantage and business with Petrobas for Technip.
• Made more than $6mn in corrupt payment to the workers’ party officials in Brazil.
• Consultant pleaded guilty to conspiracy to violate the FCPA, awaiting sentencing.

$214mn Penalty to Brazil

• In related case, company settled with Brazil authorities for $214mn for bribery.
• US will credit amount TechnipFCM pays to Brazil authorities, agreed to $214mn.

Iraq Scheme

• From 2008-2013, FMC paid bribe to at least seven government officials in Iraq.
• Officials from Iraq ministry of oil, South Oil Company, and Missan Oil Company.
• Payments made via Monaco-based intermediary company to win over business.

Deferred Prosecution

• TechnicFMC entered deferred prosecution agreement requiring rigorous internal
  controls, and to cooperate with DoJ investigation, to avoid criminal prosecution.

Remedial Action

• TechnipFMC given credit for extensive remedial measures, cooperating with DoJ.
• Disciplinary action on former and current employees in relation to its misconduct.
• Change Brazil operations, so no longer engages in practices leading misconduct.
• Required employees and third parties, to undergo additional compliance training.
• Made specific enhancement to company internal control and compliance program.

Related Enforcement Action

• In 2017, KOM and US subsidiary agreed pay $422mn to authorities in US, Brazil,
  Singapore on a related scheme, a senior legal officer pleading guilty.