SEC Settles Action Against Noble Executives Mark A. Jackson and James J. Ruehle

Securities Lawyer 101 Blog l Brenda Hamilton Attorney

On July 7, 2014, the Securities and Exchange Commission (SEC) announced that former Noble CEO Mark A Jackson and former Director and Division Manager of Noble’s Nigeria subsidiary James J. Ruehlen, have agreed to settle the SEC’s pending civil actions against them. The case had been set for a jury trial. The Court entered a final judgment in the matter on July 3, 2014.

To settle the SEC’s action against him, Jackson consented to the entry of a final judgment enjoining him from violating Section 13(b)(2)(A) of the Exchange Act as a control person pursuant to Section 20(a) of the Exchange Act.

Ruehlen agreed to the entry of a final judgment enjoining him from aiding and abetting any violation of Section 13(b)(2)(A) of the Exchange Act.

The SEC filed its complaint in February 2012 and alleged that Jackson and Ruehlen authorized the payment of bribes to customs officials to process false paperwork purporting to show the export and re-import of oil rigs, when in fact the rigs never moved.

The SEC alleged that the scheme was designed to save Noble Corporation from losing business and incurring significant costs associated with exporting rigs from Nigeria and then re-importing them under new permits. At the same time it filed its action against Jackson and Ruehlen, the SEC also filed settled charges against Thomas F. O’Rourke, who was a former controller and head of internal audit at Noble. The SEC alleged that O’Rourke helped approve the bribe payments and allowed the bribes to be booked improperly as legitimate operating expenses for the company.

In a separate civil action filed in 2010, the SEC charged Noble Corporation with FCPA violations as part of a SEC Enforcement Division sweep of the oil services industry. The company cooperated with civil and criminal investigators and agreed to pay more than $8 million in settlement.

For further information about this securities law blog post, please contact Brenda Hamilton, Securities Attorney at 101 Plaza Real S, Suite 202 N, Boca Raton, Florida, (561) 416-8956, by email at [email protected] or visit   This securities law blog post is provided as a general informational service to clients and friends of Hamilton & Associates Law Group and should not be construed as, and does not constitute, legal and compliance advice on any specific matter, nor does this message create an attorney-client relationship. Please note that the prior results discussed herein do not guarantee similar outcomes.

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Brenda Hamilton, Securities Attorney
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