Trafigura Beheer B.V.: the employee-owned parent at the centre of the enforcement cases

documentedOn 28 March 2024 the U.S. Department of Justice announced that Trafigura Beheer B.V. had pleaded guilty to conspiracy to violate the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA) over bribes to Brazilian officials to secure business with Petróleo Brasileiro S.A. (Petrobras), and would pay a criminal fine of $80,488,040 and forfeiture of $46,510,257, with up to $26,829,346 of the fine credited against amounts paid to resolve a related Brazilian investigation. ^{1 2}

response

The group's 2025 prospectus states that the conduct of former employees or agents took place about ten or more years earlier and was inconsistent with the company's principles and code of conduct, and that the DOJ credited Trafigura for cooperating and accepting responsibility.

outcome

Resolved by the plea agreement; the DOJ decided not to appoint an independent monitor.

documentedOn 28 March 2025 Brazil's Controladoria-Geral da União (CGU) and Advocacia-Geral da União (AGU) signed a leniency agreement with Trafigura Beheer B.V. under the Anti-Corruption Law (Law 12.846/2013) over improper payments to public agents between 2003 and 2014 to obtain privileged information on operations with Petrobras, providing for payment of R$ 435,410,672.26 in fines and compensation to the Union and Petrobras; the group's prospectus states that the DOJ credited USD 26.8 million towards this resolution and that the company agreed to pay an additional USD 49 million. ^{3 2}

qualification

The agreement terms are reported by a Brazilian news site from the authorities' announcement and by the group's prospectus; the agreement text is not in the record.

outcome

Resolved by agreement.

documentedOn 31 January 2025 the Criminal Chamber of the Swiss Federal Criminal Court (case SK.2023.49) convicted a former senior employee of an Angolan state-owned company of passive bribery of foreign public officials, and a commodity trading company, a former senior manager of that company and a third person through whose company the payments passed of active bribery; the court's anonymised announcement states that the judgment is not yet final and that the presumption of innocence continues to apply. ^{2 4 5 6 7}

qualification

The court's documents anonymise the parties; the company is identified as Trafigura Beheer B.V. by the matching OAG indictment, the group's own prospectus and press and NGO reports.

response

Trafigura denied bribery and said its compliance and anti-corruption measures had been independently assessed; at trial Trafigura Beheer B.V. defended itself on the basis of the compliance and anti-bribery controls it had at the time.

outcome

The first-instance judgment is not final: the company and Mike Wainwright announced appeals, and a financial news service reported in December 2025 that Trafigura had appealed; the presumption of innocence applies until a final judgment.

documentedThe operative part of the judgment found the company (designated D.a) guilty under Article 102(2) of the Swiss Criminal Code in connection with active bribery of foreign public officials, fined it CHF 3 million and imposed a compensatory claim of USD 145,634,268 in favour of the Swiss Confederation; the former senior manager (C.) received 32 months' imprisonment, 12 months to be served; the former Angolan official (A.) 36 months, 14 months to be served; and the intermediary (B.) a fully suspended 24-month sentence. ^{8 4 2 5 6 7}

qualification

The court's press release rounded the company's compensatory claim to USD 145 million; the written judgment gives USD 145,634,268.

response

Trafigura denied bribery and said its compliance and anti-corruption measures had been independently assessed; at trial Trafigura Beheer B.V. defended itself on the basis of the compliance and anti-bribery controls it had at the time.

outcome

The first-instance judgment is not final: the company and Mike Wainwright announced appeals, and a financial news service reported in December 2025 that Trafigura had appealed; the presumption of innocence applies until a final judgment.