--- title: "Trafigura Beheer B.V.: the employee-owned parent at the centre of the enforcement cases" language: en canonical: https://dossiertwist.com/dossiers/trafigura/trafigura-beheer/ as_of: 2026-10-16 keywords: ["Trafigura Pte Ltd","Trafigura Group Pte. Ltd.","Trafigura Beheer B.V.","Farringford Foundation","Trafigura Control Holdings","TPTE Holding Limited","Swiss Angola bribery case","SK.2023.49","Sonangol Distribuidora","Petrobras","Foreign Corrupt Practices Act","CFTC","Mongolia","Lex Oil","nickel fraud","Prateek Gupta","Myra Falls","Breakwater Resources","Volare Shipping","Trafigura Nat Gas"] --- # Trafigura Beheer B.V.: the employee-owned parent at the centre of the enforcement cases - Also known as: TBBV · Trafigura Beheer BV - Jurisdiction: Netherlands (NL) - Company register: 33236939 (Netherlands Chamber of Commerce (trade register)) - LEI: PX7SUPU7HUNJBQ8BPI65 **Question.** What is Trafigura Beheer B.V., how does it relate to Trafigura Pte Ltd, and which cases concern it? **Answer.** Trafigura Beheer B.V. is a Dutch company, registered since 2024 at the group's Singapore address, that is the immediate parent of Trafigura Group Pte. Ltd. and the vehicle through which about 1,400 employees hold preference shares; 99% of its votes are held by Trafigura Control Holdings. It was the group's parent until a 2015 restructuring and in 2026 was considering a move to Bermuda. It pleaded guilty in the United States in 2024 over Petrobras bribes, signed a Brazilian leniency agreement in 2025 and was convicted at first instance in Switzerland in 2025 over Angola, which it has appealed. It sits above Trafigura Pte Ltd in the ownership chain. ## Identity and history - Analysis: GLEIF records Trafigura Beheer B.V. (LEI PX7SUPU7HUNJBQ8BPI65) as an active Dutch company, trade register number 33236939, whose legal and headquarters address has been 10 Collyer Quay, Ocean Financial Centre, Singapore since a change registered on 28 May 2024. In a statement reported by a newspaper in May 2026, the company described it as a former parent of the group, set up in the Netherlands in 1993 by former employees of Marc Rich + Co and the group's parent until a 2015 restructuring in which a Singapore entity took that role. It also said Trafigura Beheer was considering moving its legal domicile to Bermuda while remaining tax-resident in Singapore; as of 15 October 2026 GLEIF still listed its jurisdiction as the Netherlands, so the record does not show that the move took place. [src-079] [src-016] ## Members and employee shares - Analysis: According to the Bulgarian regulator's 2024 report, Trafigura Beheer's members are Trafigura Control Holdings Pte. Ltd., with 99% of the voting rights, and three Jersey-registered holders, BDFH 2016 Nominee, Trafigura Trustees (Jersey) Limited and Trafigura Nominees (Jersey) Limited, whose shares and capacities the report does not give. The 2022 annual report says the shares issued to employees under its equity participation plan are preference shares with economic rights and limited voting rights, that the board of Trafigura Control Holdings decides the awards, and that Trafigura Beheer is exclusively owned by group employees. It is the immediate parent of Trafigura Group Pte. Ltd., which pays dividends to it. [src-066] [src-031] [src-001] ## The cases against it - Analysis: Trafigura Beheer B.V. was the defendant company in three bribery matters. On 28 March 2024 it pleaded guilty in the United States to conspiracy to violate the Foreign Corrupt Practices Act over bribes to Petrobras officials, with a criminal fine of $80,488,040 and forfeiture of $46,510,257. On 28 March 2025 it signed a leniency agreement with Brazil's federal authorities over the same period of payments. On 31 January 2025 the Swiss Federal Criminal Court convicted it at first instance over bribery of an Angolan state-company official, fining it CHF 3 million with a compensatory claim of USD 145,634,268; the company denied bribery and appealed, so that judgment is not final. Mark Irwin, a group board member, is described by a market-data aggregator as one of its non-executive directors. [src-045] [src-001] [src-086] [src-046] [src-070] [src-057] [src-085] [src-058] [src-033] - Documented: On 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 $26,829,346 of the fine credited against amounts paid to resolve a related Brazilian investigation. [src-045] [src-001] - Response: The group's 2025 prospectus states that the conduct of former employees or agents took place about ten or more years earlier and was inconsistent with the company's principles and code of conduct, and that the DOJ credited Trafigura for cooperating and accepting responsibility. - Outcome: Resolved by the plea agreement; the DOJ decided not to appoint an independent monitor. - Documented: On 28 March 2025 Brazil's Controladoria-Geral da União (CGU) and Advocacia-Geral da União (AGU) signed a leniency agreement with Trafigura Beheer B.V. under the Anti-Corruption Law (Law 12.846/2013) over improper payments to public agents between 2003 and 2014 to obtain privileged information on operations with Petrobras, providing for payment of R$ 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. [src-086] [src-001] - 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. - Documented: On 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. [src-001] [src-046] [src-070] [src-057] [src-085] - 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. - Documented: The 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. [src-058] [src-046] [src-001] [src-070] [src-057] [src-085] - 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. - Attributed: A market-data aggregator describes Mark Joseph Irwin as a non-executive director of Trafigura Beheer BV, a managing director of the investment holding company Farringford NV and a director of Trafigura Holdings Ltd. and Trafigura Group Pte Ltd. [src-033] - Qualification: Aggregator profile without dates; the Farringford N.V. role is not confirmed by a register extract in the record. ## Sources - [src-079] GLEIF record for Trafigura Beheer B.V. (LEI PX7SUPU7HUNJBQ8BPI65), Global Legal Entity Identifier Foundation (GLEIF), 2026-10-15 - [src-016] Media source · src-016 - [src-066] EWRC staff report on the natural-gas trading licence application of Trafigura Nat Gas Limited, Energy and Water Regulatory Commission (Bulgaria), 2024 - [src-031] Company statement source · src-031 - [src-001] Company statement source · src-001 - [src-045] Swiss Commodities Trading Company Pleads Guilty to Foreign Bribery Scheme, U.S. Department of Justice, Office of Public Affairs, 2024-03-28 - [src-086] Media source · src-086 - [src-046] Federal Criminal Court judgment in case SK.2023.49 (Angola): press release, Swiss Federal Criminal Court, 2025-01-31 - [src-070] Media source · src-070 - [src-057] Research source · src-057 - [src-085] Media source · src-085 - [src-058] Court record source · src-058 - [src-033] Corporate registry source · src-033