FCPA Compliance in the Energy Industry: Compliance Programs, Risk Mitigation and Lessons From Recent Enforcement

A live 90-minute CLE webinar with interactive Q&A

Thursday, December 13, 2018

1:00pm-2:30pm EST, 10:00am-11:30am PST

or call 1-800-926-7926

This CLE webinar will guide attorneys and compliance professionals working in the energy industry to implement and strengthen FCPA compliance programs. The panel will review recent government enforcement actions with a focus on energy companies and the lessons that can be learned from those actions. The panel will offer best practices for FCPA compliance and mitigating risks.


The nature of the energy industry—and the way it usually operates under a tender process—increases the risk of bribes. Further, the global scale of the energy sector and the complex relationships with governments, venture partners, suppliers, and other contractors make compliance with anti-bribery and anti-corruption regulation of the highest importance.

In Sept. 2018, the DOJ and the SEC reached agreement with Brazil’s state-owned energy company, Petrobras, to settle charges of FCPA violations. Petrobras agreed to pay $1.78 billion (combined) to the DOJ, SEC, Brazilian authorities and its shareholders. In 2017, one quarter of the FCPA investigations and actions were brought against energy companies.

In 2017, Halliburton settled FCPA charges with the SEC, paying $29.2 million and getting an independent client consultant to oversee its anti-corruption policies and procedures. The SEC recognized in settling that Halliburton had an FCPA compliance program, conducted and self-reported its internal investigation, and took remedial steps.

These recent FCPA enforcement actions remind counsel to the energy industry of the necessity to identify FCPA risks and implement an FCPA compliance program tailored to the company’s profile and continually evolving to address emerging compliance challenges.

Listen as our authoritative panel provides a brief review of the FCPA and discusses the risks facing the energy industry. The panel will address recent FCPA settlements with a focus on energy companies and the lessons from those settlements. The panel will offer best practices for FCPA compliance and mitigating risks.



  1. Review of the FCPA
  2. Risks for the energy industry
  3. Lessons from recent DOJ and SEC settlements
  4. Best practices
    1. FCPA compliance
    2. Risk mitigation


The panel will review these and other crucial issues:

  • What are the risk factors for companies in the energy industry that make them more vulnerable to FCPA violations?
  • What conduct has triggered SEC and DOJ investigations into potential FCPA violations?
  • What are the critical lessons from recent SEC and DOJ enforcement actions against companies in energy industry countries?
  • What are best practices for anti-corruption compliance programs and due diligence efforts?


Brown, Sharie
Sharie A. Brown

Troutman Sanders

Ms. Brown represents international corporations and conducts internal investigations, audits and transactional due...  |  Read More

Ellis, Matteson
Matteson Ellis

Miller & Chevalier

Mr. Ellis has extensive experience in all areas of international anti-corruption compliance and enforcement. With a...  |  Read More

Fava, Palmina
Palmina M. Fava

Paul Hastings

Ms. Fava conducts internal investigations with respect to the FCPA, international anti-corruption and anti-bribery...  |  Read More

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