On June 25, 2019, DOJ announced that TechnipFMC plc (“TFMC”), a publicly traded company in the United States and a global provider of oil and gas services, and its wholly owned U.S. subsidiary, Technip USA, Inc. (“Technip USA”), agreed to pay combined criminal penalties of more than $296 million to resolve foreign bribery charges with authorities in the United States and Brazil.  According to DOJ’s press release, between at least 2003 and 2013, Technip USA conspired with others to violate the FCPA by making more than $69 million in corrupt payments and “commission payments.”  Portions of these payments, DOJ alleged, were passed along as bribes to employees of Brazilian state-owned entities, in order to secure improper business advantages and obtain or retain business.

TFMC entered into a deferred prosecution agreement to two counts of conspiracy to violate the anti-bribery provisions of the FCPA.  Technip USA pleaded guilty and was sentenced on a one-count information charging it with conspiracy to violate the anti-bribery provisions of the FCPA.  DOJ noted that the monetary penalties reflected a 25% reduction from applicable Sentencing Guidelines range, given the companies’ significant cooperation and remediation efforts.

United States v. TechnipFMC plc, No. 19-cr-278 (E.D.N.Y.)
United States v. Technip USA, Inc.
No. 19-cr-279 (E.D.N.Y.)

DOJ Press Release