Oil and gas was one of the first industries the DOJ and SEC seized on when they began to focus on the FCPA a decade ago. The corruption risk profile of oil and gas companies remains high, but recent enforcement actions that appear to be the last breaths in a few wide-ranging and longstanding investigations (such as Panalpina and Oil-for-Food) have led to speculation that the government’s attention may be focused elsewhere. Paul Hastings’ Samuel Cooper, a partner based in the firm’s Houston office, shared his insights with the Anti-Corruption Report about corruption risk and FCPA compliance in the oil and gas industry, discussing, among other things, the dynamics of the traditionally high-risk profile of oil and gas companies, the effect on the industry of the early enforcement actions, what’s next for the sector, as well as advice for oil and gas companies (and others) for strengthening their compliance programs. See also “Compliance Lessons from Total S.A.’s $398 Million FCPA Settlement: Foreign Cooperation, Compliance Monitors, Broad Jurisdiction and the Effect of Reluctant Cooperation with the DOJ and SEC
” (Jun. 12, 2013).