Vitol S.A. (UN Oil-for-Food Programme)

According to the United States report to the OECD on enforcement of foreign bribery actions, "[i]n 2007, the Manhattan (NY) District Attorney’s Office charged Vitol, S.A. (Vitol), a Swiss oil trading firm, with Grand Larceny in the First Degree for its involvement in a scheme to pay kickbacks to Iraq in connection with oil purchases made under the United Nations Oil-for-Food Program (OFFP). According to court documents, while the OFFP was in effect, Vitol purchased Iraqi crude oil first as direct purchaser and later from third-parties. In June 2001, after an OPEC meeting, an agent of VITOL was told by Iraqi officials that surcharges had to be paid in order for Iraqi crude oil to be lifted.

Over the next year, VITOL paid or caused surcharges to be paid on certain oil purchases in two ways. In direct purchases, VITOL had an associated entity called Vitol Bahrain send the surcharge monies to accounts controlled by the Iraqi regime. In indirect purchases, VITOL financed the purchase of oil through third parties who then paid the surcharge to the Iraqi regime. VITOL did not inform the UN about the surcharge payments. During the period from June 2001 through September 2002, approximately $13,000,000 in surcharge monies were paid directly to the Iraqi regime in connection with crude oil purchased directly or indirectly by VITOL. [ ] On November 20, 2007, Vitol pleaded guilty and was sentenced to pay restitution of $13 million to the Iraqi people through the Development Fund for Iraq, in addition to a payment of $4.5 million in lieu of fines, forfeiture and to cover the costs of prosecution."  (Source: United States Department of Justice Report to the OECD, "Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 – February 10, 2012," Vitol S.A. matter at 101-102.)