Total S.A. allegedly paid million of dollars in bribes to intermediaries of an Iranian government official in order to win contracts to develop oil and gas fields in Iran.

Total S.A. paid $245.2 million to resolve charges of violating the Foreign Corrupt Practices Act (FCPA) by making illegal payments to a government official in Iran to obtain oil and gas concessions. As part of the agreed resolution, the Department of Justice filed a criminal information charging Total with one count of conspiracy to violate the anti-bribery provisions of the FCPA, one count of violating the internal controls provision of the FCPA, and one count of violating the books and records provision of the FCPA. Total entered into a deferred prosecution agreement for a term of three years. According to the deferred prosecution agreement, in 1995 Total sought to re-enter the Iranian oil and gas market by attempting to obtain a contract with the National Iranian Oil Company (NIOC) to develop the Sirri A and E oil and gas fields. In May 1995, Total entered into negotiations with an Iranian official who served as the chairman of an Iranian state-owned and state-controlled engineering company. Total subsequently entered into a purported consulting agreement pursuant to which Total made payments to an intermediary designated by the Iranian official to secure a development agreement with NIOC for the Sirri A and E project in July 1995. Over the next two-and-a-half years, Total paid approximately $16 million in bribes under the purported consulting agreement. In 1997, Total sought to negotiate a contract with NIOC to develop a portion of the South Pars gas field. At the direction of the Iranian official, Total and a second intermediary entered into another purported consulting agreement that called for Total to make large payments to the intermediary. In September 1997, Total executed a contract with NIOC that granted it a 40 percent interest in developing phases two and three of the South Pars gas field. Over the next seven years, Total made unlawful payments of approximately $44 million pursuant to the second purported consulting agreement. See related Total SA instance, “International Bribery – SEC Action”.