In July 2007, a grand jury indicted Jason Steph, a U.S. citizen and a former employee of Willbros International Inc. (“WII”), on charges of, inter alia, conspiracy to violate the FCPA. It is alleged that Steph, the former General Manager for WII in Nigeria conspired with others to make approximately $6 million in improper payments to various Nigerian government officials and executives of various Nigerian state-owned or state-controlled companies in order to obtain gas pipeline construction business from a joint venture controlled by the Nigerian state oil company. According to the indictment, the improper payment scheme was funded through sham consultant agreements. The indictment alleges that after the scheme was detected by the company, Steph and his co-conspirators agreed upon other potential sources to fund the improper payments to Nigerian officials, including various loans and petty cash accounts.