On December 23, 2017, Singapore was shaken by news that Keppel Offshore & Marine (KOM), a wholly-owned subsidiary of Keppel Corporation, had reached a global resolution with criminal authorities in the United States, Brazil and Singapore under which it will pay a US$422.2 million penalty for bribery-related offences in Brazil. The fine was one of the ten largest ever under the Foreign Corrupt Practices Act (FCPA) of the United States.
However, it was not only the size of the penalty that came as a shock. It was also the fact that it involved a government-linked company from Singapore, a country well known for its low level of corruption. Adding to the shock were the revelations that the illegal payments had been going on for 13 years and that they were made with the knowledge or approval of senior KOM executives, some of whom were also senior management in Keppel Corporation.
Since 2012, CPA Australia and I have collaborated in publishing an annual collection of corporate governance case studies which I edit from cases written by BBA (Accountancy) students in my Corporate Governance and Ethics and Corporate Governance and Risk Management courses at the NUS Business School, National University of Singapore. So far, six volumes have been published. Some of these cases involve issues of bribery and corruption (including money laundering). In light of the KOM scandal, I decided to publish a special collection of cases on this topic. Most of these cases have already been published in the six volumes. I have made minor changes to some of them. There are two new cases, both involving Singapore companies. One is the Keppel case. This case is longer than the other cases as I decided to publish the full version rather than the abridged version as we have been doing for other cases. I also wrote substantial parts of this case myself. This case has an earlier companion case, the Petrobras case, also included here. That earlier case was written when Keppel was mentioned as being possibly implicated, but before it truly unravelled for the group. The other new case is the “Fat Leonard” case about bribery involving the U.S. Navy Seventh Fleet and a Singapore-based company.
Unlike the case studies published in the annual case collections, I have decided not to include discussion questions. I thought it is best to have open and free flow discussion of issues around the cases.
In addition to case studies, I have over the years also written several articles on bribery and corruption in The Business Times and on my website. A selection of them has also been included.
I hope you find the cases and articles interesting and useful. The e-book can be downloaded below.
A/P Mak Yuen Teen, PhD, FCPA (Aus.)
NUS Business School
National University of Singapore
June 2018
