Action against Respondent, an oil and gas company, for misleading investors in connection with an alleged corruption scheme. According to the SEC, some of Respondent’s former senior executives, in conjunction with Respondent’s contractors and suppliers, raised the cost of infrastructure projects in order to receive kickbacks which were then paid to foreign politicians and political parties who had helped the senior executives obtain their titles with Respondent. The SEC further alleges that the former executives internally submitted misleading documents in preparation for Respondent’s SEC filings and accepted bribes from other companies in exchange for contracts or improved contract terms with Respondent. The SEC alleges that Respondent made material misstatements and omissions in various SEC filings and had insufficient controls in place to detect the scheme. Respondent has agreed to pay disgorgement of $711 million, prejudgment interest of $222,473,797, and a civil penalty of $853.2 million. Respondent has also agreed to a non-prosecution agreement with the DOJ.