Management Alert by Deptartment of Commerce on Improper Influence in the Section 232 Exclusion Request Review Process

  Buenos Aires, December  2019 Reference:    Memo by United States Department of Commerce Inspector General: “Management Alert: Certain Communications by Department Officials Suggest Improper Influence in… Read more “Management Alert by Deptartment of Commerce on Improper Influence in the Section 232 Exclusion Request Review Process”

Memorandum No. OIG-20-003-M  & Steel Tariffs

3) Besides the potential breach of FCPA and/or other laws of the United States by Tenaris (Nyse TS), steel tariffs applied by the United States may be calculated wrong in the cases were its calculations were based upon Tenaris (Nyse TS) financial statements

As Tenaris SA (Nyse TS) is oficially incorporated in Luxembourg while there is a company also named Tenaris SA incorporated in Panama and included in Panama Papers, and Tenaris SA (Nyse TS) had admitted failures in its accounting records, internal controls and compliance in two judicial procedures: i) in 2011, according to a Deferral Prosecution Agreement signed with US SEC and US DOJ (comments in the Report attached to this present email); and, ii) in 2018, according to the testimony in probe “Cuadernos Argentinos” by the CEO and Chairman of the Board of Tenaris (Nyse TS)  who testified before prosecutors in Argentina that he did not know where the allegedly payment of bribes to Venezuela -admited being paid by top managers of the Techint Group under the direct supervision of  Mr. Paolo Rocca himself- were recorded in the accountancy records and in the financial statements of the companies under his own command. Mr. Paolo Rocca also said that officers at Techint were reviewing the accounting records to find where the allegedly irregular payments were recorded (more comments in the Report attached to this present email).

To, US SEC Chairman and Commissioners: Request to investigate Tenaris (Nyse TS) – Fwd: To, The U.S. Judiciary Committee, Chairman Nadler – About, Report on Tenaris (Nyse TS), a company that may be obstructing US SEC and US DOJ on potential violation of the Laws of the United States

References:

Request to investigate Tenaris (Nyse TS), a company which can be violating FCPA and /or other laws of the United States and can be breached a DPA already signed with US SEC and DOJ
Report on Tenaris (Nyse TS), a company that may be obstructing US SEC and US DOJ on potential violation of the Laws of the United States, submitted for “The investigation into the Rule of Law” opened by House Judiciary Committee

Steel tariffs applied by the United States that were calculated based upon Financial Statements of Tenaris (Nyse TS) may be wrong, considering that: 1) Tenaris (Nyse TS) is incorporated in Luxembourg while there is a company also named Tenaris incorporated practically at the same time in Panama and included in Panama Papers; and, 2) the financial statements of Tenaris may hide serious irregularities, including -but not limited to- allegedly payment of bribes under probes “Lava Jato” and “Argentine Notebooks”

To, Argentina Anticorruption Head, Laura Alonso copy OECD/OAS/OPIC – Fwd: Info. to: OPIC – Fwd: To: House Judiciary Committe / all members of US Congress – To: United States White House, Mr. President Trump and Mr. Vice President Mr. Pence – About: Report on steel producer Tenaris (Nyse TS) potential violation of US Laws that could be affecting international steel trade and tariffs

Excerpts

As, according to media news, the interest of the Government of Argentina is to conclude the licitation of the pipeline soon, I sent the email to the attention of OPIC officers, with copy to main concerning officers at Tecpetrol and Tenaris: the CEO of Tecpetrol, Mr. Carlos Ormachea; CEO of Tenaris, Mr. Paolo Rocca, PWC Head of Argentina Mr. Santiago Mignone, Legal Counselors of Tenaris, Mr. Daniel Sullivan, Mr. Robert Risoleo, Mr. Cristian Mitrani, and members of the Board of Director of Tecpetrol who are also senior staff at Tenaris or Tecpetrol: Mr. Horacio Marín, Mr. Carlos Pappier, Mr. Ricardo Markous, Ms. Alica Móndolo and Mr. Jorge Perczyk.

Considering that the hypothesis of the Techint Group of companies -including Tenaris (Nyse TS), Techint E&C, Tecpetrol, Ternium- being covered-up by Argentina executive, judical and legislative powers will turn into a real fact if a complete investigation on the companies of the Techint Group are not completed before the licitation fo the referred pipeline is completed.

CORONAVIRUS 2019 IN CHINESE & To: President Trump, Vice President Pence – About: Report on steel producer Tenaris (Nyse TS) potential violation of US Laws that could be affecting international steel trade and tariffs

Excerpt:

As Tenaris SA (Nyse TS) is oficially incorporated in Luxembourg while there is a company also named Tenaris SA incorporated in Panama and included in Panama Papers, and Tenaris SA (Nyse TS) had admitted failures in its accounting records, internal controls and compliance in two judicial procedures: i) in 2011, according to a Deferral Prosecution Agreement signed with US SEC and US DOJ (comments in the Report); and, ii) in 2018, according to the testimony in probe “Cuadernos Argentinos” by its CEO and Chairman of the Board, considering that while the declaration by Mr. Paolo Rocca starts by page 35 in fine (“Voy a declarar…. ) out of 42 pages; there is a question by Prosecutors about the origin of the money that was for the irregular payments to which P. Rocca said that he did not know, as the money came from the “central entities” of the Techint Group (sociedades centrales del Grupo Techint) and he is in charge only of the “operative entites” of the Techint Group and not of “central entities”. Mr. Paolo Rocca did not said who is in charge of the “central entities”, and Prosecutors did not make a new question on the issue. Paolo Rocca also said that officers at Techint are reviewing the accounting records to find where the allegedly irregular payments were recorded (more comments in the Report); Tenaris (Nyse TS) may have been masking its accounting records for its filings of financial statements to US SEC, since long time ago.