A few months after the DOJ declined to prosecute, the SEC announced that it has resolved its FCPA charges against Hyperdynamics for a $75,000 penalty.  On September 29, 2015, the SEC issued a Cease-and-Desist Order finding that the small oil and gas exploration company’s insufficient internal controls resulted in payments to third parties owned by a Guinean employee of the company. The penalty reflects Hyperdynamics cooperation and remediation efforts and perhaps the lack of any bribery allegations, but that number is dwarfed by the $12.7 million Hyperdynamics’ reported that it spent on the FCPA investigation of its African operations.  Scott Wilson, a partner at Boies, Schiller & Flexner, told the Anti-Corruption Report that this settlement “highlights that there are anti-corruption compliance risks even for a very small firm,” and Daniel Fetterman, a partner at Kasowitz, Benson, Torres & Friedman, emphasized that the lack of direct bribery allegations is not all that unusual.  See also “How Can Companies Capture the Telecom, Energy and Resources Opportunity in Africa While Mitigating the Risk?”  (Oct. 9, 2013).