In September 2007, the SEC announced a settled FCPA enforcement action against Bristow Group, Inc. (Bristow), a publicly held, Houston based, operator of oil and gas production facilities and helicopter transportation services. The Commission found that from approximately 2003 - 2004, Bristow's wholly-owned U.S. subsidiary, AirLog International, Ltd. (AirLog), through its Nigerian affiliate, Pan African Airlines Nigeria Ltd. (PAAN), made improper payments totaling approximately $425,000 to employees of two Nigerian states to influence the officials to reduce the amount of taxes payable by PAAN in Nigeria. These payments were: (i) made with the knowledge and approval of PAAN senior employees; (ii) approved by at least one former senior officer of Bristow; and (iii) because the payments were booked as "payroll tax expenses," not properly recorded in AirLog's books and records which were consolidated into Bristow's books and records. Based on this conduct, the Commission found that Bristow violated the anti-bribery, books and records, and internal control provisions of the FCPA and ordered Bristow to cease and desist from future violations of the FCPA. In resolving the matter, the SEC specifically noted Bristow's prompt remedial acts taken upon discovery of the improper payments and its cooperation with the Commission.
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