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ARTICLE · 16 MAY 2014

All Facially Good Deeds May Not Go Unpunished

Hughes Hubbard & Reed LLP
Hughes Hubbard & Reed LLP
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Hughes Hubbard & Reed LLP

Hughes Hubbard & Reed LLP

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On March 13, 2014, Tullow Oil announced that it was suspending further funding and activities related to a drilling concession in Guinea.

United StatesGovernment, Public Sector

Hyperdynamics Corporation Investigated For Charitable Contributions

On March 13, 2014, Tullow Oil ("Tullow") announced that it was suspending further funding and activities related to a drilling concession in Guinea until the resolution of an investigation into potentially corrupt activities by its partner – Hyperdynamics Corporation ("Hyperdynamics"). Tullow's actions follow a September 30, 2013 announcement by Hyperdynamics that the United States Department of Justice ("DOJ") is investigating whether the company illegally obtained and retained certain drilling concession rights in Guinea, with particular focus on charitable contributions made by the company, in potential violation of the U.S. Foreign Corrupt Practices Act ("FCPA") or U.S. anti-money laundering statutes. The company has publicly disclosed that the U.S. Securities and Exchange Commission ("SEC") has also issued a subpoena in connection with the investigation. While not the first case in which the

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