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130e po3.cc (Rev. 05-01-2008) UNCLASSIFIED FEDERAL BUREAU OF INVESTIGATION Precedence: ROurINE Date: 05/10/2011 To: San Diego. From: San Diego Squad wC3 Contact: SA b6 Approved By: b7C Drafted By: Case ID #: 205-SD-72665 (Pending Title: SEMPRA ENERGY.; FOREIGN CORRUPT PRACTICES ACT Synopsis: To document investigative activity regarding FcpA allegations against Sempra Energy (Sempra or the Company). Details: On 05/06/2011, attorney with Day law firm, review by Assistant Unjted. Attorney (AusA) and FBI Special Agents and the opinion Ietter regaraing tne rormation of a charitable trust by Sempra for the benefit of the Ensenada community. Sempra was not willing to allow the Department of Justice to retain a copy of the letter, b6 so as not to waive any attorney/client privilege in the on-going b7C inquiry regarding potential violations of the Foreign Corrupt Practices Act (FcpA) by Sempra in Mexico.. The letter, dated 03/26/2004, provided a review of the. proposed trust's operating rules and provided an opinion as to whether the trust could constitute 'a violation of the FcpA. and opined, based on the trust's-operating-rules,. noting that the rules specifically mention prohibitions of benefits to family members of the trust members and government officials, and require all actions to be in compliance with FcpA, that the trust was not in danger of violating the provisions of FcpA. The letter further asserted that all major project. permits, including land use permits, required to be. issued by the City of Ensenada had already been issued, thus eliminating any concern that the funding of the trust was contingent upon the granting of essential permits by the City.. UNCLASSIFIED 8os-s0-7a<65,1h