In February 2009 KBR LLC pleaded guilty to FCPA charges over bribery schemes tied to Nigeria’s Bonny Island LNG project, paying a $402 million criminal fine, while Halliburton and KBR resolved parallel SEC cases with about $177 million in disgorgement. DOJ and SEC papers describe TSKJ joint-venture commission conduits. The Archive keeps that settlement spine separate from Iraq-era political conflation.