James C. Ho "If left intact, the decision below may force employers to make the difficult decision not to disclose all of the details in relation to potential FCPA violations as soon as they are aware of them," said Ho, a partner at Gibson, Dunn & Crutcher in Dallas. The case has its origins in a Department of Justice investigation into a scheme to bribe Nigerian customs officials in connection with a Shell oil and gas project. Royal Dutch Shell in 2010 agreed to pay $48 million in penalties as part of a larger settlement involving other oil and gas service companies accused of paying bribes to import equipment and vessels into Nigeria and other foreign counties. Robert Writt, a former Shell engineer, was in charge of approving the reimbursement requests of a contractor hired to import equipment. According to Writt's brief, he raised concerns about suspect invoices and only paid them when instructed to do so by his supervisor.