On November 5, 2019, Frank’s International N.V., a Netherlands-based global provider of tubular running services and specialty well construction, stated in a filing with the US Securities and Exchange Commission that a previously disclosed investigation by the SEC and US Department of Justice into potential FCPA violations remained ongoing. The investigation, which the Company first disclosed in a June 2016 SEC filing, concerns the operations of certain Frank’s subsidiaries in West Africa.In June 2016, Frank’s voluntarily disclosed to the DOJ, SEC and “other governmental entities” that it had undertaken an extensive internal review of these possible FCPA violations, and that it intended to cooperate fully with these agencies. In its November 5 filing, Frank’s stated that it intends to continue to cooperate with these authorities and that it remains unable to predict the outcome of any final resolution.
Frank’s also disclosed that in the course of its investigation it had discovered and disclosed historical business transactions that may have been subject to US and other international sanctions. In 2018, the Company received No Action Letters from both the Office of Foreign Assets Control of the US Department of the Treasury and the Bureau of Industry and Security, Office of Export Enforcement of the US Department of Commerce regarding these transactions.