The SEC has been investigating Angolan presalt company Cobalt International Energy, a US company, since November 2011. In late April 2012, reports surfaced that the company has links to Angolan officials and to Angolan company Nazaki Oil and Gas.

These allegations raise the prospect of FCPA violations, as Cobalt has “long disclosed” that certain of its partners in Angola may expose it to liability under the FCPA. Cobalt has indicated, however, that its ties to Nazaki have not caused it to violate the FCPA or any Angolan law.