Foreign Corrupt Practices Act
FCPA enforcement in the Energy, Power & Commodities sector remains one of the U.S. Department of Justice and U.S. Securities and Exchange Commission's most consistent prosecution priorities, with state-owned utility counterparties and national oil company relationships drawing direct scrutiny under the statute's anti-bribery and books-and-records provisions. Commodity traders, independent power producers, and oilfield service firms operating in high-risk jurisdictions across West Africa, Southeast Asia, and Latin America have seen third-party intermediary liability drive the bulk of recent enforcement actions.
Watch
- DOJ Corporate Enforcement Policy: self-disclosure credit eligibility for energy sector acquirers post-M&A
- State-owned enterprise classification: which foreign utility counterparties trigger FCPA 'foreign official' exposure
- SEC accounting fraud charges tied to off-book payments in LNG project development
- Third-party due diligence gaps in commodity trading intermediary contracts under active DOJ review
- Pilot Program on Voluntary Self-Disclosures (2023): deadline pressures for firms in ongoing internal investigations
Recent material activity in Energy, Power & Commodities
Active monitoring in place across Energy, Power & Commodities. Material developments related to foreign corrupt practices act will appear here as they are published.