On October 17, 2019, the global commodities trading company Gunvor International BV was ordered to pay CHF 94 million (about $95.5 million) to Swiss authorities following the company’s October 14 conviction on bribery-related charges. Specifically, the Swiss Office of the Attorney General (OAG) demonstrated that Gunvor failed to take all reasonable measures in order to prevent the bribery of public officials in the Ivory Coast and the Republic of Congo. The bribes were paid to allow Gunvor to “gain access” to the countries’ petroleum markets. The OAG stated that during the relevant period (2008-2011), the company did not have a code of conduct, a compliance program, an internal audit procedure, or compliance training for employees. According to the OAG, Gunvor also failed to take measures to manage the risks inherent in the use of third-party agents, including failing to have a formal selection process for third parties, and did not heed warning signs that improper payments were being made. Warnings signs that were ignored included substantial payments to offshore companies “unrelated to oil activities,” and the backdating of documentation provided to banks.
Several individuals, including a former Gunvor employee, are currently under investigation for bribing foreign public officials, money laundering, and “criminal mismanagement,” according to the OAG.