On November 19, 2018, the SEC issued an order against Vantage Drilling International, stating: "These proceedings arise from violations of the internal accounting control provisions of the Foreign Corrupt Practices Act of 1977 (the "FCPA"), 15 U.S.C. § 78m(b)(2)(B), by Vantage Drilling Company ("VDC"). Specifically, VDC failed to devise a system of internal accounting controls with regard to VDC's transactions with VDC's former outside director, largest shareholder, and only supplier of drilling assets ("Director A"), and failed to properly implement internal accounting controls related to its use of third-party marketing agents."

On November 19, 2018, the SEC issued a press release regarding charges against Vantage Drilling International, stating: "According to the SEC's order, VDC lacked sufficient internal accounting controls in relation to the heightened risk of conducting business in the oil and gas industry in Brazil. Consequently, VDC increased the risk that it financed the bribes by making substantial payments to the director in 2008 and 2012. Both VDC and the director financially benefited from the lucrative contract with Petrobras that was secured through the director's and agent's bribery."