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U.S. v. Jason Edward Steph

 
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Willbros - Steph, Jason Edward
:
DOJ Criminal
:
July 19, 2007
:
U.S. v. Jason Edward Steph
:
U.S. v. Jason Edward Steph, No. 4:07-cr-00307-1 (S. D. Tex. 2007)
:
Despite discovery through an internal investigation of certain aspects of the improper activities, Steph and others thereafter devised new schemes to improperly obtain cash in Nigeria to honor preexisting "commitments" for the purpose of making continued illegal payments to Nigerian officials.

On account of his cooperation, Steph was allowed to plead to conspiracy, which capped his sentence at 5 years, while non-cooperating defendants were charged with 7 offenses each carrying a sentence of up to 5 years.
:
Energy (Non-Utility)-Oil & Gas-Other/Multi
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Nigeria
:
2003; 2004; 2005
:
1) Officials of state-owned Nigerian National Petroleum Corporation (NNPC); 2) officials of NNPC's subsidiary National Petroleum Investment Management Services (NAPIMS); 3) officials of NNPC's majority-owned joint venture operator, Shell Petroleum Development Company of Nigeria (SPDC); 4) a senior official in the executive branch of the Nigerian federal government; and 5) officials in the dominant political party in Nigeria.
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Steph, from 2002-2005 the General Manager - Onshore in Nigeria for Willbros International, Inc. ("WII"), the wholly owned subsidiary of Willbros Group, Inc. ("WGI"), was part of a multi-million dollar bribery scheme to pay foreign officials of the Nigerian government-owned oil companies to obtain oil and gas pipeline construction business. After WII undertook an internal investigation in January 2005 that led to the resignation of a central WII executive responsible for Nigerian business and stopped payments to consultants in Nigeria, Steph and others were involved in a scheme to find other funding sources for outstanding "commitments" WII subsidiaries had made to Nigerian officials, including using falsely-obtained petty cash to pay a $1.85 million bribe in February and March 2005.

On July 19, 2007, the DOJ filed an indictment against Steph charging one count of conspiracy to violate the FCPA and for three money laundering counts. In November 2007, Steph pled guilty to the FCPA Conspiracy charge. Under the plea agreement, Steph is obligated to cooperate with the government’s ongoing investigation of the Willbros matters. Steph also agreed to pay back taxes. The plea agreement did not include sentencing stipulations but the government did not oppose Steph's request for a two-level downward adjustment under the sentencing guidelines.
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Conspiracy - Anti-Bribery
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Conspiracy - Money Laundering
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Plea
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On January 28, 2010, the court sentenced Steph to 15 months of imprisonment, 2 years of supervised release, a criminal fine of $2,000 and an assessment of $100.
:
2,100
:
15
:
Agent of Domestic Concern, Agent of Issuer, Domestic Concern, Employee of Domestic Concern
:
General Manager
:
U.S.
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Contract Procurement/Retention
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387,500,000
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Cash, Wire/check
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Sales Agent/Consultant
:
6,000,000
:
Nigeria
:
Nigeria
:
The plea agreement indicates that Steph was a "knowing" participant in the bribery conspiracy because he included the anticipated consultant payments of 3% of project revenue as an expense in the internal EGGS project budget taken from the original "bid run" which he personally made, approved, and negotiated. He did so knowing that the consultants were engaged in corrupt negotiations with Nigerian officials and that they would use some or all of the consultancy fees to make improper payments to those officials in order to assist in obtaining and retaining the EGGS business for the Willbros subsidiaries.
:
No