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Chemicals
Boca Raton, FL, United States
Nationality of Foreign Officials: Brazil, Ecuador, Venezuela
Summary of Allegations:
Between 2010 and 2018, according to the DOJ press release, Sargeant Marine and its affiliated companies bribed foreign officials in Brazil, Venezuela, and Ecuador in exchange for inside information and procurement contracts with state-owned and state-controlled companies in these countries. To disguise the bribery schemes, Sargeant Marine adopted a system of code names about the target officials’ identities, and utilized intermediaries, fake consulting agreements, and shell companies in transferring the bribes.
Brazil
Sargeant Marine bribed multiple high-level government officials, including a Minister in the government, a Congress member, and a Petrobras executive to secure asphalt contracts. It concealed the scheme by entering into fake consulting agreements with intermediaries in control of offshore shell company bank accounts. The intermediaries received bribes from Sargeant Marine via the accounts and took a portion to bribe Brazilian officials on behalf of Sargeant Marine.
Venezuela
Between 2012 and 2018, Sargeant Marine bribed four PDVSA officials to ensure PDVSA would designate asphalt procurement contracts to a Sargeant Marine nominee. Sargeant Marine covered the officials’ identities by code names and utilized the tactics as in Brazil to disguise the nature of the bribes.
Ecuador
In around 2014, Sargeant Marine bribed a Petro Ecuador official to secure an asphalt supply contract with the same tactics it adopted in Brazil and Venezuela. In addition, the intermediary it employed was closely affiliated to a Petro Ecuador decisionmaker.
Approximate Alleged Payments to Foreign Officials: Unspecified
Business Advantage Allegedly Obtained: Government contracts and inside information
Agencies: United States: Department of Justice
Results: Plea Agreement, Prosecution of Individuals
Year Resolved: 2020
Compliance Monitor:
Ongoing: No
Details:
On 22 September 2020, Sargeant Marine pleaded guilty to charges under conspiracy to violate the anti-bribery provision of the Foreign Corrupt Practices Act (“FCPA”), and agreed to pay a criminal fine of US$16.6 million to resolve the charges.
The DOJ unsealed indictments of the following individuals involved in the bribery schemes:
Daniel Sargeant – Sargeant Marine senior executive;
Jose Tomas Meneses – Sargeant Marine trader;
Luiz Eduardo Andrade – the intermediary bribed Brazilian officials on behalf of Sargeant Marine;
David Diaz – the intermediary bribed Venezuelan officials on behalf of Sargeant Marine;
Hector Nuñez Troyano – former PDVSA official and bribe recipient relating to contracts in Venezuela;
Roberto Finocchi – Sargeant Marine trader involved in the Brazil scheme.
Discovery Method: Unspecified
Details:
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