The Tanker Trucks & The front-men

In my previous posts, I showed that the Internal Audit Report of Eni’s Brazilian subsidiary confirmed “fictitious invoicing”, the destruction of documents, similar transactions, and other serious facts at the Cuiabá unit.

But my whistleblowing report was not limited to invoices issued in TELEMAT’s name (Brasil Telecom).

Among the facts presented in my dossier was the existence of tanker trucks linked to the then Regional Sales Manager of Cuiabá.

These vehicles were incorporated into Agip’s transport fleet and were used for two activities directly connected to the company’s business:
🔹 delivering fuel to customers in the State of Mato Grosso;
🔹 transferring gasoline and ethanol from facilities in São Paulo to Cuiabá.

In other words, the trucks performed services paid for by Agip itself and took part in an essential stage of the company’s operations: transporting the products it sold.

The information and documents gathered in my report also indicated that some of these vehicles may have been acquired through “fictitious financing” granted to Agip customers who allegedly participated in the fraud and corruption scheme I had reported.

The arrangement described was serious: financing formally granted to fuel retailers may have been used to fund the purchase of trucks later employed to transport the company’s own products.

Despite this, the Internal Audit Report dated July 26, 2001, neither identified nor examined:
🔹 how many trucks were linked to the Regional Sales Manager;
🔹 in whose names the vehicles were registered;
🔹 how they had been financed;
🔹 which customers had received the funds;
🔹 how much Agip paid for deliveries and product transfers;
🔹 who the ultimate economic beneficiaries of those payments were.

The documents I later examined raised a fundamental question: why did the audit fail to identify the carrier, the tanker trucks linked to the Cuiabá Regional Sales Manager, and the fuel retailers who allegedly received fictitious financing?

📌 How could an audit of Agip’s largest regional sales unit in Brazil fail to investigate the vehicles used to transport the company’s own products and the source of the funds used to acquire them?

The information concerning these trucks and transport operations required a thorough review of vehicle ownership records, contracts, financing arrangements, payments, and ultimate beneficiaries.

None of this appears in the report’s conclusions.

Once again, the problem is not only what Internal Audit found.

The problem is everything it failed to follow up, investigate, and document.


✅ Learn more:

1️⃣ Agip do Brasil Internal Audit Report:
🔹 original in Portuguese
🔹 English translation

2️⃣ Chronology of Facts for the Reconstruction of the Events

3️⃣ Memorial (1999–2025)

The Service Stations & The front-men

In my previous post, I showed that the Internal Audit Report of Eni’s Brazilian subsidiary confirmed “fictitious invoicing”, destroyed documents and other irregular transactions in Cuiabá.

But one fundamental issue was left out of its conclusions.

In the whistleblowing report submitted to the Commercial Directorate, I stated that the then Regional Sales Manager was allegedly operating two service stations owned by Agip through third parties - the so-called “front men.”

This fact was later recorded in a Public Notarial Declaration by the then President of Sindipetroleo Mt, who confirmed that he had reported it to Agip’s Commercial Director and General Manager of Internal Audit during the investigation conducted in Cuiabá.

Despite this, the report dated July 26, 2001, did not examine:
🔹 who effectively managed the service stations;
🔹 who received the financial proceeds from their operations;
🔹 the links between the formal operators and the regional manager;
🔹 any potential conflict of interest involving the use of company assets.

Months later, another internal document emerged, which I obtained in 2021 under Brazil’s Access to Information Law - applicable to the Brazilian state-owned company Petrobras, which succeeded Eni in the ownership of its Brazilian assets.

On February 7, 2002, Internal Audit itself informed the CEO of Agip do Brasil that the former regional manager did not appear in the official documentation of the two service stations, as would be expected in an operation conducted through third parties.

The memorandum was produced six days after I invoked the Ethics Committee and reiterated that the irregularities also extended to the operational area, despite the dismissal of the Regional Manager and four of his seven sales executives.

The question is unavoidable:

📌 If the operation of these service stations had been reported in June 2001, why was it neither investigated nor recorded before my dismissal?

And furthermore:

📌 Why did Internal Audit address the issue only months later, after a new report to the Ethics Committee?

The presence of third parties in the documents does not, by itself, prove who the ultimate beneficiary was.

But it represented a risk that an independent audit should have identified, investigated and documented.

The problem is not only what the report found.

The problem is everything it failed to examine.


✅ Learn more: Read the documents:

1️⃣ Internal Audit Report:
🔹 Portuguese
🔹 English

2️⃣ Public Notarial Declaration by the then President of Sindipetróleo-MT
🔹 Portuguese
🔹 English

3️⃣ Internal Audit Memorandum to the CEO (Feb 7, 2002)
🔹 Portuguese
🔹 English