On December 22, 2017, Keppel Offshore & Marine Ltd. (“KOM”) and its wholly owned U.S. subsidiary, Keppel Offshore & Marine U.S.A. Inc. (“KOM USA”), agreed to pay a combined total penalty of more than $422 million to resolve charges with authorities in the United States, Brazil, and Singapore arising out of a scheme to pay bribes to Brazilian officials.  In addition, on the same day, KOM USA pled guilty in the Eastern District of New York to a one-count criminal Information charging the company with conspiracy to violate the anti-bribery provisions of the FCPA.  KOM is a Singapore-based company that operates shipyards and repairs and upgrades shipping vessels.  According to admissions and court documents, KOM conspired to violate the FCPA by paying approximately $55 million in bribes to Brazilian officials in order to win 13 contracts with Petrobras, a state-owned oil company, and another Brazilian entity.  To conceal the payments, KOM paid commissions under the guise of consulting agreements to an intermediary, who then made payments to Brazilian officials.  As part of a deferred prosecution agreement, in addition to paying the penalty, KOM must implement internal controls and continue to cooperate with the United States’ ongoing investigation.  A former senior member of KOM’s legal department also pled guilty to conspiracy to violate the FCPA on August 29, 2017.  United States v. Keppel Offshore & Marine Ltd., 17-cr-697 (E.D.N.Y.); United States v. Keppel Offshore & Marine, USA, 17-cr-698 (E.D.N.Y.)

DOJ Press Release