Wait Until Next Time: Noble Corp. Executives and SEC Settle Pending Litigation on Eve of Trial, Leaving Basic FCPA Questions Unanswered

On July 3, 2014, only a week before trial was scheduled to begin, a former Noble Corp. (Noble) CEO Mark Jackson and the former Nigeria country manager, James Ruehlen, agreed to settle the US Securities and Exchange Commission’s (SEC) pending enforcement action for violations of various provisions of the US Foreign Corrupt Practices Act (FCPA). These settlements represent some of the last pending enforcement actions arising from the US government’s enforcement efforts against Panalpina World Transport (Holding) Ltd. (Panalpina) and certain of its customers relating to payments made through customs brokers to government officials in Nigeria and other countries to secure temporary importation permits and extensions necessary to allow their drilling rigs and other equipment to operate in Nigeria.

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