FCPA Opinion Procedure Release 04-02 came from an investor group of JPMorgan Partners Global Fund, Candover 2001 Fund, 3i Investments plc, who were acquiring certain companies and assets from ABB Ltd. relating to ABB’s upstream oil, gas, and petrochemical businesses. On July 6, 2004, the DOJ announced guilty pleas to violations of the Foreign Corrupt Practices Act [“FCPA”] entered in the United States District Court for the Southern District of Texas by ABB Vetco Gray, Inc. and ABB Vetco Gray (UK) Ltd., two of the entities being acquired by the Requestors.
These guilty pleas came after the Requestor’s diligence on ABB and discovery of the FCPA issues.
This Release was to prevent future liability of the requestor for the prior violations of ABB.