As with the antibribery provisions, penalties and fines can be brutal. There has been a recent spate of FCPA enforcement actions against U.S. companies. For oil companies trying to figure out how to comply with the FCPA, Triton Energy is perhaps the most instructive case. Triton Energy was the first time in a decade that the SEC punished a company for violating the FCPA's accounting provisions. Coincidentally, the target of the Government's attention was an oil company.
Triton is an international oil exploration and production company with headquarters in Dallas.
Triton operated an oil field in Indonesia through a subsidiary. The subsidiary hired a local consultant to exploit his influence with the Indonesian government. Over several years, the subsidiary used the consultant to funnel money to government auditors. B. Some Lessons Oil companies can learn quite a bit from Triton's mistakes. Other lessons can be gleaned from the FCPA's structure.