Lawyer in the Middle

On the Friday before Christmas, the DOJ slapped Singapore-based Keppel Offshore & Marine and its U.S. subsidiary with a $422 million criminal penalty for paying $55 million in bribes to Brazilian officials.

It immediately made the FCPA Blog’s Top 10 list as the seventh biggest FCPA enforcement action ever. Most interesting, however, was the identity of a mystery man in the middle of the mess, identified by the feds as a “former senior member” of Keppel’s legal department. Jeffrey Chow, who worked for Keppel in Singapore for 25 years, admitted drafting the contracts that overpaid an agent who bribed the Brazilian officials. Chow then flipped and helped the feds nail the company and other executives. “I should have refused to draft the contract,” Keppel said, “and I should have resigned from Keppel.”