On February 11, 2009, the SEC filed a complaint against Halliburton and KBR, Inc. The SEC stated: "This action arises from multiple violations of the Foreign Corrupt Practices Act (the "FCPA") of the federal securities laws by Defendants Halliburton Company and KBR, Inc."

The SEC announced "settlements with KBR, Inc. and Halliburton Co. to resolve SEC charges that KBR subsidiary Kellogg Brown & Root LLC bribed Nigerian government officials over a 10-year period, in violation of the Foreign Corrupt Practices Act (FCPA), in order to obtain construction contracts. The SEC also charged that KBR and Halliburton, KBR's former parent company, engaged in books and records violations and internal controls violations related to the bribery."

The court stated: "The Securities and Exchange Commission having filed a Complaint and Defendant Halliburton Company ("Halliburton") having entered a general appearance; consented to the Court's jurisdiction over Halliburton and the subject matter of this action; consented to entry of this Final Judgment without admitting or denying the allegations of the Complaint (except as to jurisdiction); waived findings of fact and conclusions of law; and waived any right to appeal from this Final Judgment."