UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934 

Release No. 99589 / February 23, 2024

ADMINISTRATIVE PROCEEDING

File No. 3-21816

In the Matter of

Brooge Energy Limited, Nicolaas 

Lammert Paardenkooper, and Lina 

Saheb,

Respondents.

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EXTENSION ORDER

The Division of Enforcement (“Division”) has requested an extension of time until 

November 29, 2024, to submit a Proposed Plan of Distribution under Rule 1101(a) of the 

Commission’s Rules on Fair Fund and Disgorgement Plans, 17 C.F.R. § 201.1101(a).

On December 22, 2023, the Commission issued an Order Instituting Cease-and-Desist 

Proceedings, Pursuant to Section 8A of the Securities Act of 1933 and Section 21C of the 

Securities Exchange Act of 1934, Making Findings, and Imposing a Cease-and-Desist Order (the 

“Order”)1 against Brooge Energy Limited (“Brooge”), a publicly-traded company that owns and 

operates an oil storage facility in Fujairah, United Arab Emirates; and its former CEO, Nicolaas 

Lammert Paardenkooper (“Paardenkooper”) and its former Chief Strategy Officer and Interim 

CEO, and Lina Saheb (“Saheb”) (collectively, the “Respondents”). In the Order, the 

Commission found that Brooge went public through a special purpose acquisition company 

(“SPAC”) transaction in December 2019. Before and after going public between thirty (30) and 

1

 Securities Act Rel. No. 11260 (Dec. 22, 2023).
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eighty (80) percent of Brooge’s revenues were unsupported and materially misstated from 2018 

through early 2021. Subsequent to the SPAC transaction, Brooge registered the offer and sale of 

up to $500 million in different types of securities with the Commission and an affiliate of the 

company issued $200 million of 5-year senior secured bonds in the Nordic bond market. 

Additionally, the Commission found that Paardenkooper and Saheb knew, or were reckless in 

not knowing, of this accounting fraud. 

The Commission ordered Brooge to pay a civil money penalty of $5,000,000.00 and 

ordered Paardenkooper and Saheb to each pay a civil money penalty of $100,000.00, for a 

collective total of $5,200,000.00 to the Commission. The Commission also created a Fair Fund, 

pursuant to Section 308(a) of the Sarbanes-Oxley Act of 2002, so the penalties collected can be 

distributed to harmed investors (the “Fair Fund”).

The Fair Fund consists of the $5,200,000.00 collected from the Respondents. The Fair 

Fund has been deposited in a Commission-designated account at the U.S. Department of the 

Treasury, and any accrued interest will be added to the Fair Fund.

In its request for an extension of time, the Division states that additional time is needed 

locate and verify contact information for investors, compile investor records, complete the fund 

administrator solicitation and appointment process, develop the distribution methodology, and 

prepare the proposed plan of distribution.
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Accordingly, for good cause shown, IT IS HEREBY ORDERED that the Division’s 

request for an extension of time until November 29, 2024 to submit a Proposed Plan of 

Distribution is granted.

For the Commission, by the Division of Enforcement, pursuant to delegated authority.2

Vanessa A. Countryman

Secretary

2

 17 C.F.R. § 200.30-4(a)(21)(i).