TotalEnergies SE

On 29 May 2013, the U.S. Department of Justice charged Total S.A., now TotalEnergies SE, with FCPA books-and-records and internal-controls violations and entered a deferred prosecution agreement carrying a $245.2 million criminal penalty. The government alleged that Total paid approximately $60 million through intermediaries between 1995 and 2004 to obtain oil and gas rights in Iran. In a parallel civil settlement, the SEC said Total agreed to disgorge $153 million. A deferred prosecution agreement is not a guilty plea; this summary characterizes the disposition as a settlement and the payment theory as the government's allegation. Primary sources: https://www.justice.gov/archives/opa/pr/french-oil-and-gas-company-total-sa-charged-united-states-and-france-connection-international and https://www.sec.gov/newsroom/press-releases/2013-2013-94htm