Rolls-Royce: Iraq bribery in its global FCPA/DOJ resolution over South Oil Company gas turbines (from 2006 to 2009; resolved 2017)

Rolls-Royce plc's January 2017 global bribery resolution (with the US Department of Justice, the UK Serious Fraud Office and Brazilian prosecutors) is among the largest corporate bribery settlements on record. In the DOJ's own information and deferred prosecution agreement, separate from the SFO's non-Iraq settlement, Rolls-Royce admitted that from about 2006 to 2009 its Energy business supplied gas turbines or generators to Iraq's state-owned South Oil Company, and that when Iraqi officials raised quality concerns and threatened to blacklist the company from future Iraqi business, an intermediary reported in the press to be Unaoil paid bribes to Iraqi officials to get the equipment accepted and avert the blacklisting; Rolls-Royce and its US subsidiary RRESI made over $1.5m profit as a result. Iraq is one of five countries named in the DOJ's part of the resolution (with Thailand, Kazakhstan, Azerbaijan and Angola); the DOJ's $170m criminal penalty and a separate SEC or other-country total are not broken out by country. No individual, Iraqi or otherwise, was named as personally prosecuted over the Iraq conduct.