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Halliburton SEC order over Angola local content contracts (2017)

Last checked: 23 October 2026 · Case records

On 27 July 2017 the U.S. Securities and Exchange Commission issued a settled order against Halliburton Company and former vice president Jeannot Lorenz over contracts in Angola 1,2. Halliburton agreed to pay US$14 million in disgorgement, US$1.2 million in prejudgment interest and a US$14 million penalty, US$29.2 million in all 1. The SEC found violations of the FCPA books and records and internal accounting controls provisions 1. Both consented "without admitting or denying the findings" 2.
Resolution type
Settled SEC administrative order, Administrative Proceeding File No. 3-18080 2
Date
27 July 2017 1,2
Agency
U.S. Securities and Exchange Commission 1
Release numbers
Exchange Act Release No. 81222, Accounting and Auditing Enforcement Release No. 3884, Administrative Proceeding File No. 3-18080, press release 2017-133 1,2
Respondents
Halliburton Company and Jeannot Lorenz 2
Total amount
US$29.2 million from Halliburton 1
Breakdown
US$14,000,000 disgorgement, US$1.2 million prejudgment interest, US$14,000,000 civil penalty 2
Individual penalty
US$75,000 civil penalty for Jeannot Lorenz 1,2
Statutes, Halliburton
Exchange Act Sections 13(b)(2)(A) and 13(b)(2)(B), codified at 15 U.S.C. 78m(b)(2) 2,3
Statutes, Lorenz
Sections 13(b)(2)(A), 13(b)(2)(B) and 13(b)(5) and Rule 13b2-1 2
Admission
Respondents consented "without admitting or denying the findings herein", except as to jurisdiction and subject matter 2
Status
Independent compliance consultant for 18 months. Completion not confirmed for this page 2

The SEC order

The SEC said Halliburton was "Paying $29.2 Million to Settle FCPA Violations" 1. The order states that the respondents submitted offers of settlement and that the Commission "has determined to accept" them 2.

Halliburton must pay US$14,000,000 in disgorgement, US$1.2 million in prejudgment interest and a US$14,000,000 civil penalty "within 14 days of the entry of this Order" 2. Jeannot Lorenz must pay a US$75,000 civil penalty in two parts, US$20,000 within 14 days and US$55,000 "within 364 days of the entry of this Order" 2. The SEC press release describes the Lorenz penalty as "for causing the company's violations" 1.

Halliburton must retain an independent compliance consultant within 90 days and keep the consultant "for a period of eighteen (18) months" 2. The consultant reviews Halliburton's anti-corruption policies for its operations in Africa, including local content and single-source justification controls 2.

Conduct described in the order

These are SEC findings in a settled order. The respondents did not admit or deny them 2.

The SEC said that in 2008 officials at Sonangol, the Angolan state oil company, told Halliburton it needed to partner with more Angolan-owned businesses to meet local content rules 1. Halliburton put Lorenz in charge of that effort 1.

The SEC said Lorenz sought to retain a local Angolan company owned by a former Halliburton employee who was a friend and neighbour of the Sonangol official who would approve the contract awards 1. It said the contracts were designed to meet local content requirements, not the scope of work, and that the process skipped competitive bidding and a control requiring special committee review of contracts over US$10,000 in high-risk countries such as Angola 1.

The order says Halliburton paid US$3,705,000 to the local company between April 2010 and April 2011 2. The payments were made under a September 2009 interim consulting agreement and a May 2010 real estate transaction management agreement 2. The SEC said Sonangol approved seven subcontracts for Halliburton and that Halliburton made about US$14 million in profit from them 1.

The law applied

The order does not charge bribery. It finds violations of the accounting provisions of the Securities Exchange Act 1,2. Section 13(b)(2)(A) requires issuers to "make and keep books, records, and accounts, which, in reasonable detail, accurately and fairly reflect the transactions" of the issuer 3. Section 13(b)(2)(B) requires a system of internal accounting controls 3. Section 13(b)(5), applied to Lorenz, says "No person shall knowingly circumvent or knowingly fail to implement a system of internal accounting controls" 2,3.

Associate Director Antonia Chion of the SEC Enforcement Division said "Companies and their executives must comply with these internal accounting controls" 1.

Earlier history and other agencies

The order recalls that in February 2009 Halliburton settled with the SEC over a bribery scheme by its former subsidiary KBR, Inc. 2. The order says Halliburton then agreed to a final judgment barring future books and records and internal controls violations and, jointly with KBR, gave up US$177 million 2. It says KBR paid a US$382 million criminal fine in a parallel DOJ matter 2. The 2009 DOJ release gives the agreed fine as US$402 million 4. This page reports both figures as each source states them.

The SEC thanked "the U.S. Department of Justice and the Federal Bureau of Investigation" for their help 1. This page has not confirmed any DOJ action in the Angola matter.

Common questions

Did Halliburton admit wrongdoing in Angola?

No. Halliburton and Lorenz consented to the order "without admitting or denying the findings" 2.

How much did Halliburton pay the SEC in 2017?

US$29.2 million: US$14 million disgorgement, US$1.2 million interest and a US$14 million penalty 1.

Was Halliburton charged with bribery?

No. The SEC found violations of the FCPA books and records and internal accounting controls provisions 1.

Who was Jeannot Lorenz?

A former Halliburton vice president who agreed to a US$75,000 penalty 1.

Rules and fees change. Check the official site linked above before you apply or pay. Spotted an error? Email [email protected] with the official link.

Sources

  1. U.S. Securities and Exchange Commission: press release 2017-133, Halliburton Paying $29.2 Million to Settle FCPA Violations (27 July 2017)
  2. U.S. Securities and Exchange Commission: Order, In the Matter of Halliburton Company and Jeannot Lorenz, Release No. 81222, File No. 3-18080 (27 July 2017)
  3. Legal Information Institute, Cornell Law School: 15 U.S.C. 78m, Periodical and other reports
  4. U.S. Department of Justice: Kellogg Brown & Root LLC Pleads Guilty to Foreign Bribery Charges and Agrees to Pay $402 Million Criminal Fine, press release 09-112 (11 February 2009)

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