SEC v. John Samson, John G. A. Munro, Ian N. Campbell, and John H. Whelan (D.D.C. 2006)
Case Details
- Case Name
- SEC v. John Samson, John G. A. Munro, Ian N. Campbell, and John H. Whelan (D.D.C. 2006)
- Foreign Official
- Officials of the National Petroleum Investment Management Services (“NAPIMS”), the state-owned agency which oversees investment in petroleum.
- Date of Conduct
-
1999 to 2001
- Nature of Business
- John Samson is the former West Africa regional sales manager for Vetco Gray Nigeria Ltd., John G. A. Munro is the former senior vice president of operations for Vetco Gray (U.K.) Ltd., Ian N. Campbell is the former vice president of finance for Vetco Gray (U.K.) Ltd., and John H. Whelan is a former vice president of sales for Vetco Gray, Inc. During the relevant time period, Vetco Gray Nigeria, Vetco Gray (U.K.) Ltd., and Vetco Gray, Inc.—all oil services providers—were subsidiaries of ABB, a Swiss corporation and global provider of power and automation technologies whose ADRs are traded on the NYSE. Notably, Whelan is the only U.S. citizen among the defendants in this action. Samson, Munro, and Campbell are citizens of the United Kingdom.
- Influence to be Obtained
- According to the complaint filed by the SEC on July 5, 2006, from 1999 through 2001, the defendants offered, approved, and paid bribes to NAPIMS officials in furtherance of ABB’s bid to obtain a $180 million contract to provide equipment for an oil drilling project. In addition, the defendants disguised the payments on ABB’s books as legitimate consulting expenses through the creation of false business records.
- Enforcement
- Without admitting or denying the allegations in the complaint, Samson, Munro, Campbell, and Whelan consented to the entry of final judgments that (1) permanently enjoin each of them from future violations of the FCPA, (2) order each to pay a civil monetary penalty ($50,000 as to Samson, and $40,000 each as to Munro, Campbell, and Whelan), and (3) orders Samson to pay $64,675 in disgorgement and prejudgment interest.
- Amount of the Value
- Approximately $1 million.
- Amount of Business Related to Payment
- Approximately $180 million.
- Reporting Requirements
- No
- Total Combined Monetary Sanction
- $ 170,000
Defendants
John Samson
- Citation
- SEC v. Samson et al., No. 1:06 cv 01217 (D.D.C. 2006).
- FCPA Statutory Provision
-
- Aiding and Abetting: Books-and-Records
- Aiding and Abetting: Internal Controls
- Other Statutory Provision
- None
- Disposition
- Plea Agreement
- Defendant Jurisdictional Basis
- Agent of Issuer
- Defendant's Citizenship
- United Kingdom
John G. A. Munro
- Citation
- SEC v. Samson et al., No. 1:06 cv 01217 (D.D.C. 2006).
- FCPA Statutory Provision
-
- Aiding and Abetting: Books-and-Records
- Aiding and Abetting: Internal Controls
- Other Statutory Provision
- None
- Disposition
- Plea Agreement
- Defendant Jurisdictional Basis
- Agent of Issuer
- Defendant's Citizenship
- United Kingdom
Ian N. Campbell
- Citation
- SEC v. Samson et al., No. 1:06 cv 01217 (D.D.C. 2006).
- FCPA Statutory Provision
-
- Aiding and Abetting: Books-and-Records
- Aiding and Abetting: Internal Controls
- Other Statutory Provision
- None
- Disposition
- Plea Agreement
- Defendant Jurisdictional Basis
- Agent of Issuer
- Defendant's Citizenship
- United Kingdom
John H. Whelan
- Citation
- SEC v. Samson et al., No. 1:06-cv-01217 (D.D.C. 2006).
- FCPA Statutory Provision
-
- Aiding and Abetting: Books-and-Records
- Aiding and Abetting: Internal Controls
- Other Statutory Provision
- None
- Disposition
- Plea Agreement
- Defendant Jurisdictional Basis
- Agent of Issuer
- Defendant's Citizenship
- United States
