Defendant Name: Brooge Energy Limited

Defendant Type: Public Company
SIC Code: 9999
CUSIP: G1611B10

Initial Case Details

Legal Case Name In the Matter of Brooge Energy Limited, Nicolaas Lammert Paardenkooper, and Lina Saheb
First Document Date 22-Dec-2023
Initial Filing Format Administrative Action
File Number 3-21816
Allegation Type Issuer Reporting and Disclosure
AAER 4480

Violations Alleged

Exchange Act
Sec 10(b) + Rule 10b-5
Rule 12b-20
Sec 13(a)
Rule 13a-1
Sec 13(b)(2)(A)
Sec 13(b)(2)(B)
Sec 14(a)
Rule 14a-9
Securities Act
Sec 17(a) (Not specified)
Other
Rule 13a-16 Exchange Act
Additionally, Nicolaas Lammert Paardenkooper is alleged to have caused Brooge Energy Limited's violation of Rule 12b-20 of the Exchange Act.
Lina Saheb is alleged to have caused Brooge Energy Limited's violation of Rule 12b-20 of the Exchange Act.
Nicolaas Lammert Paardenkooper is alleged to have caused Brooge Energy Limited's violation of Sec 13(a) of the Exchange Act.
Lina Saheb is alleged to have caused Brooge Energy Limited's violation of Sec 13(a) of the Exchange Act.
Nicolaas Lammert Paardenkooper is alleged to have caused Brooge Energy Limited's violation of Rule 13a-1 of the Exchange Act.
Lina Saheb is alleged to have caused Brooge Energy Limited's violation of Rule 13a-1 of the Exchange Act.
Nicolaas Lammert Paardenkooper is alleged to have caused Brooge Energy Limited's violation of Sec 13(b)(2)(A) of the Exchange Act.
Lina Saheb is alleged to have caused Brooge Energy Limited's violation of Sec 13(b)(2)(A) of the Exchange Act.
Nicolaas Lammert Paardenkooper is alleged to have caused Brooge Energy Limited's violation of Sec 14(a) of the Exchange Act.
Lina Saheb is alleged to have caused Brooge Energy Limited's violation of Sec 14(a) of the Exchange Act.
Nicolaas Lammert Paardenkooper is alleged to have caused Brooge Energy Limited's violation of Rule 14a-9 of the Exchange Act.
Lina Saheb is alleged to have caused Brooge Energy Limited's violation of Rule 14a-9 of the Exchange Act.
Nicolaas Lammert Paardenkooper is alleged to have caused Brooge Energy Limited's violation of Rule 13a-16 Exchange Act.
Lina Saheb is alleged to have caused Brooge Energy Limited's violation of Rule 13a-16 Exchange Act.

Resolutions

First Resolution Date 22-Dec-2023
Headline Total Penalty and Disgorgement $5,000,000

Related Documents:

33-11260 22-Dec-2023 Administrative Proceeding
Order Instituting Cease-and-Desist Proceedings, Pursuant to Section 8A of the Securities Act of 1933 and Section 21C of the Securities Exchange Act of 1934, Making Findings, and Imposing a Cease-and-Desist Order
On December 22, 2023, the SEC instituted cease-and-desist proceedings against Brooge Energy Limited, Nicolaas Lammert Paardenkooper, and Lina Saheb stating: "These proceedings arise out of an accounting and offering fraud by Brooge, which is a publicly-traded company that owns and operates an oil storage facility in Fujairah, United Arab Emirates."
2023-256 22-Dec-2023 Press Release--Administrative Proceeding
SEC Charges UAE-Based Brooge Energy and Former Executives with Fraud
On December 22, 2023, the SEC "announced fraud charges against Brooge Energy Limited, a publicly-traded energy company located in the United Arab Emirates, the company’s former CEO, Nicolaas Lammert Paardenkooper, and its former Chief Strategy Officer and Interim CEO, Lina Saheb."
34-99589 23-Feb-2024 Administrative Proceeding
Extension Order
The Commission ordered that: "the Division’s request for an extension of time until November 29, 2024 to submit a Proposed Plan of Distribution is granted."
34-99901 03-Apr-2024 Administrative Proceeding
Order Appointing Tax Administrator
The Commission ordered that: "Miller Kaplan Arase LLP is appointed as the Tax Administrator for the QSF in the above-referenced proceeding."
34-101068 17-Sep-2024 Administrative Proceeding
Order Appointing Fund Administrator, Setting Administrator's Bond Amount, and Authorizing the Approval and Payment of Fees and Expenses of Administration
The Commission ordered that: "A. Rust is appointed as the Fund Administrator . . . ; B. Rust shall obtain a bond . . . in the amount of $5,200,000.00; C. The Fund Administrator will submit invoices to the Commission staff for services rendered . . . ; and D. At the direction of an Assistant Director of the Office of Distributions, OFM is authorized to pay the Fund Administrator's fees and expenses from the Fair Fund . . . , so long as the total amount paid to the Fund Administrator, including the invoice to be paid, does not exceed the total amount of the approved cost proposal submitted by the Fund Administrator."
34-101757 26-Nov-2024 Administrative Proceeding
Notice of Proposed Plan of Distribution and Opportunity for Comment
The Commission stated: "Notice is hereby given . . . that the Division of Enforcement has submitted to the Commission a proposed plan of distribution (the “Proposed Plan”) for the distribution of monies paid in the above-captioned matter."
34-101757-pdp 26-Nov-2024 Administrative Proceeding
Proposed Plan of Distribution
The Commission stated: "The Division of Enforcement submits this Proposed Plan of Distribution (the “Plan”) to the United States Securities and Exchange Commission (the “Commission”) . . . . This Plan provides for the distribution of a Fair Fund (the “Fair Fund”), comprised of civil money penalties collected from Brooge Energy Limited (“Brooge”), Nicolaas Lammert Paardenkooper (“Paardenkooper”), and Lina Saheb (“Saheb” and collectively, “Respondents”) in the above-captioned matter."

Other Defendants in Action: