The first individual prosecutions arising from the Panalpina FCPA matters – which were settled in the Fall of 2010 and involved freight forwarder Panalpina and several oil & gas companies upon whose behalf Panalpina paid bribes to customs officials have now been filed, in this case by the SEC.  Specifically, three former executives of Noble Corporation, an oil services company, have been charged:  the former CEO, the former managing director for Noble’s operations in Nigeria, and the former head of internal audit.  The SEC alleges that these former executives had a role in arranging, facilitating, approving, making, and/or concealing the bribe payments to induce Nigerian customs officials to grant certain permits illegally and to favorably exercise or abuse their discretion to grant permit extensions.  The former CEO allegedly approved the bribe payments and concealed the payments from Noble’s audit committee and auditors. The former Nigeria manager allegedly prepared false documents, sought approval for the bribes, and processed and paid the bribes.  The former head of internal audit settled with the SEC for a $35K fine and an agreement to a permanent injunction against him regarding further violations of the FCPA. The former CEO and Nigeria managing director say they will litigate the charges.  See SEC Litig. Release 2012-32, SEC Charges Three Oil Services Executives With Bribing Customs Officials in Nigeria (Feb. 24, 2012).