Defendant Name:
Total, S.A.
Defendant Type:
Public Company
SIC Code:
1311
CUSIP:
89151E10
Document Reference:
34-69654
Document Details
Legal Case Name
In the Matter of Total, S.A.
Document Name
Order Instituting Cease-and-Desist Proceedings Pursuant to Section 21C of the Securities Exchange Act of 1934, Making Findings, and Imposing a Cease-and-Desist Order
Document Date
29-May-2013
Document Format
Administrative Proceeding
AAER
3461
Allegation Type
Foreign Corrupt Practices Act
Document Summary
On May 29, 2013, the SEC issued an order instituting cease-and-desist proceedings pursuant to Section 21C of the Exchange Act regarding Total, S.A.'s FCPA violations. According to the SEC: "From approximately September 1995 to November 2004, Total and others paid approximately $60 million in unlawful payments to intermediaries for the purpose of inducing an Iranian government official (the 'Iranian Official') to use his influence to assist Total in connection with obtaining contracts to develop the Sirri A and E oil fields and two phases of the South Pars oil and gas field in Iran. Between 1995 and 2004 the Iranian Official was first the head of one wholly owned subsidiary of the National Iranian Oil Company ('NIOC') and later the head of another NIOC wholly owned subsidiary. The Iranian Official was also a government advisor to a high-ranking Iranian official. Total made these payments at the direction of the Iranian Official to intermediaries through a consulting and services agreement and subsequent amendments, entered into with an intermediary designated by the Iranian Official ('Intermediary One')." On May 29, 2013, the SEC announced that it had accepted Total S.A.'s offer of settlement and imposed a cease-and-desist order.
Disgorgement & Penalty Information
Resolutions
Cease and Desist Order
Compliance Related Independent Consultant
Other Compliance Related Undertaking
Monetary Penalties:
Disgorgement
Individual:
$153,000,000.00
Shared: