Defendant Name:
Total, S.A.
Defendant Type:
Public Company
Document Reference:
2013-94
Document Details
Legal Case Name
In the Matter of Total, S.A.
Document Name
SEC Charges Total S.A. for Illegal Payments to Iranian Official
Document Date
29-May-2013
Document Format
Administrative Proceeding
Allegation Type
Foreign Corrupt Practices Act
Document Summary
On May 29, 2013, the SEC announced that it charged France-based oil and gas company Total S.A. ("Total") with violating the Foreign Corrupt Practices Act by paying $60 million in bribes to intermediaries of an Iranian government official who then exercised his influence to help the company obtain valuable contracts to develop significant oil and gas fields in Iran. According to the SEC's order instituting settled administrative proceedings, Total attempted to cover up the true nature of the illegal payments by entering into sham consulting agreements with intermediaries of the Iranian official and mischaracterizing the bribes in its books and records as legitimate "business development expenses" related to the consulting agreements. The SEC alleges that Total had inadequate systems to properly review the consulting agreements and lacked sufficient internal controls to comply with federal laws prohibiting bribery. Total agreed to pay more than $398 million to settle the SEC's charges and as part of a deferred prosecution agreement in a parallel criminal matter.
Disgorgement & Penalty Information
Resolutions
Cease and Desist Order
Compliance Related Independent Consultant
Various Undertakings