Settlements

ST-302
Paradigm, B.V.
Paradigm, B.V.
United States
Department of Justice
China, Indonesia, Kazakhstan, Mexico, Nigeria
2007
09/24
Unknown
Legal Person
Criminal
Non-Prosecution Agreement
Criminal Fine
$1,000,000.00
$1,000,000
$0
Art.16, Art.23, Art.26
Art. 1, Art. 2, Art. 7
Bribery of foreign officials
Bribery of foreign officials
Yes
According to the US Department of Justice Report to Congress, Appendix C "Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010," Paradigm BV, at 82-83, accessed at www.justice.gov/criminal/fraud/fcpa/docs/response3-appx-c.pdf: Misconduct involved corrupt payments to employees of state-owned oil and gas companies in China (2006), Indonesia (2003), Kazakhstan (2005-2006), Latvia [dates not given], Mexico (2004-2005), and Nigeria (2003-2005). Resulting criminal enforcement action: In Re Paradigm B.V. (November 24, 2007). Settlement amount: Criminal fine of $1 million. The involved misconduct is detailed in the Statement of Facts attached to the Non-prosecution agreement, which also noted that Paradigm is a Dutch Limited Liability Company, which moved its principal place of business in 2005 to Houston. (Source: In Re Paradigm BV, Non-prosecution agrement and statement of facts (September 21, 2007). According to the June 2011 United States Report to the OECD, "In one instance, the company paid $22,250 into the Latvian bank account of a British West Indies company recommended as a consultant by an official of KazMunaiGas, Kazakhstan's national oil company, to secure a tender for geological software. [ ] Paradigm also used an agent in China to make commission payments to representatives of a subsidiary of the China National Offshore Company in connection with the sale of a software [ ] Paradigm also admitted to similar conduct in dealings in Mexico, Indonesia, and Nigeria." (Source: US Report to the Organisation for Economic Co-operation and Development, "Steps taken to implement and enforce the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions," Information as of May 31, 2011, Paradigm B.V. Case Summary at 98-99.)