In re El Paso Corp. (2007)

• Case Name
• In re El Paso Corp. (2007)

• Date Filed
• 02/05/2007

• Enforcement Agency
• DOJ

• Countries
• Iraq

• Foreign Official
• None

• Date of Conduct
• 2001 to 2002

• Nature of Business
• Purchase of Iraqi oil by El Paso Corporation (“El Paso”), a U.S. corporation.  The Coastal Corporation (“Coastal”) was the predecessor-in-interest to El Paso CGP Company, which now operates as a wholly-owned subsidiary of El Paso.

• Influence to be Obtained
• From June 2001 through May 2002, El Paso purchased Iraqi oil from third parties, who had paid approximately $5.48 million in illegal surcharges to the former government of Iraq.  

• Enforcement
• On February 7, 2007, the United States Attorney for the Southern District of New York and El Paso entered into a non-prosecution agreement, under which El Paso agreed to forfeit the sum of $5,482,363, equal to the sum of illegal surcharges paid to the former Iraqi government.  The Office of Foreign Assets Control (“OFAC”) agreed not to pursue civil penalties against El Paso for any violations of OFAC sanctions programs related to El Paso’s participation in the former Iraqi government’s scheme.  El Paso also settled a related complaint filed by the SEC, consenting to a civil penalty of $2.25 million.

• Amount of the Value
• Approximately $5.48 million.  

• Amount of Business Related to Payment
• Approximately $420 million in oil purchases.

• Intermediary
• Third-Party Iraqi Oil Companies.  

• Total Sanction
• $ 5,482,363

• Compliance Monitor
• No

• Reporting Requirements
• No

• Case is Pending?
• No

• Related Enforcement Actions
• SEC v. El Paso Corp. (S.D.N.Y. 2007)  
  

El Paso Corp. 

• Citation
• In re El Paso Corp. (2007).

• Date Filed
• 02/05/2007

• Filed Under Seal
• No

• FCPA Statutory Provision

• Other Statutory Provision
• Wire Fraud

• Disposition
• Non-Prosecution Agreement

• Defendant Jurisdictional Basis
• Unknown

• Defendant's Citizenship
• United States