Extractive Industries/Mining/Oil & Gas


London, United Kingdom


Nationality of Foreign Officials: Brazil, Iraq

Summary of Allegations:

London-based oil and gas services company TechnipFMC plc (“TechnipFMC”) was formed in January 2017 via the merger of Technip S.A. (“Technip”) and FMC Technologies, Inc. (“FMC Technologies”). TechnipFMC has admitted that its predecessor companies were involved in two separate bribery schemes: one in Brazil involving Technip and one in Iraq involving FMC Technologies.

Under the Technip bribery scheme which took place between 2003 to 2014, executives from Technip and its U.S. subsidiary Technip USA Inc. (“Technip USA”) and a Brazil-based joint venture owned 25% by Technip USA and 75% by Keppel Offshore & Marine Ltd. (“KOM”) paid nearly US$ 69 million in bribes via a third-party consultant to various Brazilian government officials from Brazilian government-owned Petróleo Brasileiro S.A. (“Petrobras”) and the Worker’s Party of Brazil. The bribes were funneled through the consultant as “commission” payments and were paid for the purpose of securing improper business advantages from the Brazilian government officials. Technip also corruptly hired the children of various Brazilian government officials as favors in exchange for business advantages. Technip earned approximately US$ 135.7 million in ill-gotten profits from the scheme. 

In the FMC Technologies bribery scheme, which took place from 2008 to 2013, FMC Technologies executives, via an intermediary company, paid bribes to various Iraqi government officials in connection with seven government service contracts to obtain and retain business within Iraq.  FMC Technologies and related entities earned nearly US$ 5.3 million in projects as a result of the scheme.

Approximate Alleged Payments to Foreign Officials: over US$ 69 million in bribes, improper hiring of family members of government officials.

Business Advantage Allegedly Obtained: business advantages in Brazil and Iraq including contract awards.


Agencies: Brazil: Advogado-Geral da União (AGU), Brazil: Controladoria-Geral da União (CGU) , Brazil: Public Prosecutor's Office / Ministerio Publico Federal (MPF)
Results: Criminal Fine
Year Resolved: 2019
Compliance Monitor:
Ongoing: No

25 June 2019 - The DOJ, in its deferred prosecution agreement, referenced that TechnipFMC reached a settlement with Advogado-Geral da União (AGU), the Controladoria-Geral da União (CGU) and the Ministério Público Federal (MPF) over bribes paid in Brazil, through which TechnipFMC will pay a total of US$ 214.3. The DOJ credited this amount towards the criminal fine it imposed. 

Agencies: United States: Department of Justice
Results: Criminal Fine, Deferred Prosecution Agreement
Year Resolved: 2019
Compliance Monitor: No
Ongoing: No

25 June 2019 - TechnipFMC entered into a three-year deferred prosecution agreement (“DPA”) with the DOJ and was charged with two counts of conspiracy to violate the anti-bribery provisions of the FCPA.  Per the terms of the DPA, the company is required to pay a total criminal fine of US$ 296.2 million, of which US$ 81.9 million will be paid to the United States Treasury and of which US$ 500,000 will be paid as a criminal fine on behalf of Technip USA, who for its part, pleaded guilty to violating the FCPA in connection with the resolution. TechnipFMC received a US$ 214.3 million credit for the balance of the total criminal fine, equal to the amount TechnipFMC must pay to Advogado-Geral da União (AGU), the Controladoria-Geral da União (CGU) and the Ministério Público Federal (MPF) over bribes paid in Brazil pursuant to a separate resolution.  The DPA also requires TechnipFMC to annually report on its remediation and implementation of agreed upon compliance measures.


TechnipFMC plc (formed in January 2017 via the merger of Technip S.A. (“Technip”) and FMC Technologies, Inc. (“FMC Technologies”).