ERHC Energy Inc (ERHE)

[midtieroil]

Yes it would be a violation of the FCPA in both the EU and in the US if CEPSA or ERHC were making backroom deals involving paying off public officials as some here suggested may be happening. I never said it was happening. In fact I clearly said CEPSA would not be stupid enough to engage in that type of conduct. No need to worry about ERHC doing it because they have no money.

And yes it is a violation of Section 16 of the Exchange Act if any person surpasses the filing threshhold and fails to report that ownership whether they are a foreign person or not. In case you didn't know, ERHC trades on a US exchange.
Did you forget that?

The penalty for failure to file depends somewhat upon the intent. If the intent is to deliberately hide ownership from other investors and shareholders while secretly gaining control through market purchases that would break numerous statutes and the penalties could be severe and even criminal.

Hope that clears it up for you. Always happy to help a fellow investor understand the basics of investing.

If you have further questions I would suggest you read Section 16 of the Exchange Act. You might also look at some of the cases brought by the government against violators. Some just involve fines or penalties and others are criminal prosecutions.

Do you need me to give you a link to Section 16 or do you know how to find it?