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Report claims Flotek provided incomplete information to consultant who evaluated CnF in 2016 and that evaluation technique was inadequate; FourWorld analyses using complete data and proper controls demonstrates impact on well production from CnF is zero; analysis estimates attrition of CnF users since 2012 is 85 percent; full report, Flotek: Drilling Down to Zero, available at

FourWorld Capital Management, LLC has completed an independent analysis of the principal product of Flotek Industries Inc. (NYSE: “FTK”, “Flotek”), challenging the efficacy and value of the fracking additive known as CnF.

Houston-based Flotek, a supplier of specialty chemicals to the oil and gas industry, markets CnF as a high-potency fracking additive that it claims enhances the extraction of oil and natural gas from horizontal wells by 30% to 70% relative to similar additives. Touted as its “crown jewel,” CnF has long been Flotek’s primary driver of revenue and profitability, which is sold to operators of hydraulic fracturing oil and gas wells across the United States.  Flotek sells CnF at a premium that is multiples of the price of widely available generic surfactants.

New York-based FourWorld Capital is an SEC-registered investment advisor focusing on event-based investments prompted by specific tax, legal or regulatory drivers. The firm was founded by John Addis, formerly head of Americas Equity Finance at Bank of America Merrill Lynch.

FourWorld’s analysis reveals that Flotek overstates the impact of CnF on well productivity. In addition, an analysis using publicly available data on oil and gas wells shows the vast majority of major oil and gas producers have discontinued their use of CnF products in well completions in recent years.

“Through a painstaking analysis of CnF performance – using publicly available data on shale production from the leading industry data sources – we found that CnF has no measurable impact on oil production in fracked wells,” Mr. Addis stated.

Among its findings on CnF, FourWorld’s investigation has determined that:

  • Flotek may not have provided critical information to an independent consulting firm, MHA Petroleum Consultants, commissioned by a special committee of the Flotek Board of Directors to evaluate the product earlier this year. FourWorld contends that the resulting study, published by Flotek this past January, was based on incomplete data and used an evaluation technique that failed to control for key variables in the oil extraction process.
  • Employing evaluation techniques that properly control for the key variables in the oil production process (e.g., location, well length, water and sand volume), the estimated impact of CnF on oil production is indistinguishable from zero. The analysis covered the same focus areas indicated in DJ Basin report from MHA commissioned by Flotek.
  • Studies of CnF use in fracking completions from a nationwide database of over 117,000 well sites from over 1,000 oil and gas operators across 25 states, shows nearly 85% of the end users of CnF products since November 2012 are no longer using Flotek’s CnF product in their reported well completions. Among these are major operators like Anadarko Petroleum, Devon Energy, Aera Energy and ConocoPhilips, who all rank in the top ten operators by overall well count in the database during the study period.
  • In recent earnings presentations, Flotek highlights the “resilience” of CnF sales volumes stemming from its broadening base of CnF customers. FourWorld’s analysis shows the growing concentration of CnF use by just three operators – due to changes in well design – has masked the true level of CnF end user attrition, and demonstrates that consumption by new operators has been minimal.
  • Flotek’s financial condition is heavily dependent on CnF. FourWorld believes anyone reviewing the Company should carefully consider the impact on Flotek’s income statement if CnF sales were materially reduced from either a reduction in pricing more in line with competitor products or a decline in volumes from existing customers.

As of the publication date of the report, FourWorld, and FourWorld managed accounts, have a direct or indirect short position in Flotek stock, and stand to realize significant gains in the event the price of Flotek stock declines. The consulting firms hired by FourWorld, and referenced in the report, are receiving a fee based on the performance of FourWorld’s positions in Flotek stock, and, independent of FourWorld, may have a direct or indirect short position in Flotek stock.

Incomplete list of CnF trade names provided by Flotek helped overstate product’s efficacy

FourWorld believes that the list of trade names provided by Flotek to MHA, a Denver based consulting firm hired by a special committee of the Flotek Board of Directors, was incomplete and materially affected the results of their study in Denver-Julesburg Basin of Colorado. MHA relied on these trade names in order to determine which wells had Flotek’s CnF products in them. The trade names present in the focus areas of the published study include at least two CnF products not present on the list provided by Flotek, which accounted for an estimated 22% of CnF wells in the focus areas reported to show materially improved results from CnF. Without these additional trade names, wells that used CnF would be misclassified as wells not using the product.

Using its own comprehensive data set of wells in the same focus areas of the DJ Basin, FourWorld shows the impact of mislabeling these wells in a simple control study, like the one conducted by MHA, is material. The largest number of mislabeled wells in the data-set belonged to Noble Energy. The MHA study was commissioned by the Special Technical Committee, a committee formed from Flotek’s own Board of Directors, which was tasked with handling an SEC inquiry into Flotek marketing practices and evaluating the efficacy of CnF. Among the members of the Flotek Board is Ted D. Brown, senior vice president of Noble’s Northern Region, including operations in the DJ Basin, until January 31, 2015.

FourWorld’s own comparative study of 604 wells in the DJ basin shows no CnF benefit

FourWorld, working closely with two Houston-based energy and performance measurement consultants, RK Trading LLC and Sylvania LLC, tested CnF extensively using various methods.

The group performed analyses to evaluate the performance of wells located in the eastern Colorado section of the DJ Basin, the area reported in the study published by Flotek to show the highest levels of oil production outperformance from wells labeled as using a CnF product compared to wells determined not to contain a CnF product by MHA.

These analyses demonstrate that simply controlling for the key variables known to affect oil production, such as well length, location, water volume, sand use and operator, reveals that the estimated effect of CnF on oil production is indistinguishable from zero. In simpler terms, where and how you frack the well matters.

RK and Sylvania used robust regressions and Generalized Additive Models to demonstrate that production in the DJ Basin wells varies systematically with these key variables. The analysis indicates that all of the outperformance of wells using a CnF product was attributable to variable affecting oil production, and not the presence of CnF. RK and Sylvania indicate similar conclusions have been obtained for a large sample of wells completed in the Permian Basin, one of the most prolific oil and gas producing regions in the country.

An analysis of a publicly available database shows 85% attrition of CnF end users

Using FracFocus, the industry standard source for finding chemical data on oil and gas wells, FourWorld conducted a study of over 117,000 well sites from over 1,000 operators in 25 states to evaluate the use of CnF in fracking completions.  The results of FourWorld’s analyses show that of the 334 operators who have used CnF in any well completion over the last four years, nearly 85% of them no longer report using a CnF product in well completions. Among them are major operators like Anadarko Petroleum Corp. (APC), EOG Resources Inc. (EOG), Devon Energy Corp. (DVN), Aera Energy LLC and ConocoPhilips (COP). FourWorld analysis shows 160 of 183 operators are no longer using CnF products in well completions when the analysis is limited to horizontal fracked wells only.

Flotek highlights new CnF customers while avoiding the turnover among existing users: “{T}he base of CnF users broadened meaningfully in the third quarter” Flotek CFO John Chisholm said in a 3rd Quarter 2016 earnings call. Analysis of Flotek’s own presentation materials from an industry conference in November 2016 shows evidence of customer turnover of nearly 70% since the start of 2014, while the operator study described above shows a similar yet slightly higher attrition rate of 85% of CnF end users. Furthermore, using FracFocus data, FourWorld has identified just 19 “new” CnF end users in 2016, who have completed a combined total of 50 wells with CnF out of the 285 total well completed in the period.

FourWorld believes Flotek’s new customers have been almost exclusively smaller operators with minimal revenue potential. Water usage studies conducted by FourWorld show that the top three users of CnF have propped up CnF sales volumes despite a massively fall in CnF well completion counts for operators outside the top three, which highlight a worsening customer concentration problem and calls into question Flotek’s claims of a broadening customer base and accelerated adoption of CnF chemistries.

The collaboration of FourWorld, RK Trading and Sylvania produced multiple studies to measure the efficacy on CnF under strict variable controls. This powerful combination brought together expertise in data collection, database management, and statistical analysis of well chemistry and completion design.

Dr. Jefferis, partner at RK Trading and consulting statistician, added, “The analysis is very cut and dried. We evaluated the DJ Basin data using several different approaches, and obtained the same answer in every case. Once you recognize that a well completed by someone who has already drilled several hundred wells in a given location is bound to behave differently than a well completed by party who has much less local experience, and acknowledge the challenge of pushing oil through an 8,000-ft. wellbore, the results more or less fall into your lap.”

FourWorld’s full thesis, along with a white paper authored by RK Trading and Sylvania discussing their regression analysis and generalized additive model study, are available at

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Taking control of compliance: how FS institutions can keep up with the ever-changing regulatory landscape



Taking control of compliance: how FS institutions can keep up with the ever-changing regulatory landscape 1

By Charles Southwood, Regional VP – Northern Europe and MEA at Denodo

The wide-spread digital transformation that has swept the financial services (FS) sector in recent years has brought with it a world of possibilities. As traditional financial institutions compete with a fresh wave of challenger banks and fintech startups, innovation is increasing at an unprecedented pace.

Emerging technologies – alongside the ever-evolving concept of online banking – have provided a platform in which the majority of customer interactions now take place in a digital format. The result of this is a never-ending stream of data and digital information. If used correctly, this data can help drive customer experience initiatives and shape wider business strategies, giving organisations a competitive edge.

However, before FS organisations can utilise data-driven insights, they need to ensure that they can adequately protect and secure that data, whilst also complying with mandatory regulatory requirements and governance laws.

The regulation minefield

Regulatory compliance in the FS sector is a complex field to navigate. Whether its potential financial fraud or money laundering, risk comes in many different forms. Due to their very nature – and the type of data that they hold – FS businesses are usually placed under the heaviest of scrutiny when it comes to achieving compliance and data governance, arguably held to a higher standard than those operating in any other industry.

In fact, research undertaken last month discovered that the General Data Protection Regulation (GDPR) has had a greater impact on FS organisations than any other sector. Every respondent working in finance reported that the changes made to their organisation’s cyber security strategies in the last three years were, at least to some extent, as a result of the regulation.

To make matters even more confusing, the goalpost for 100% compliance is continually moving. In fact, between 2008 and 2016, there was a 500% increase in regulatory changes in developed markets. So even when organisations think they are on the right track, they cannot afford to become complacent. The Markets in Financial Instruments Directive (MiFID II), the requirements for central clearing and the second Payment Service Directive (PSD2), are just some examples of the regulations that have forced significant changes on the banking environment in recent years.

Keeping a handle on this legal minefield is only made more challenging by the fact that many FS organisations are juggling an unimaginable amount of data. This data is often complex and of poor quality. Structured, semi-structured and unstructured, it is stored in many different places – whether that’s in data lakes, on premise or in multi-cloud environments. FS organisations can find it extremely difficult just to find out exactly what information they are storing, let alone ensure that they are meeting the many requirements laid out by industry regulations.

A secret weapon

Modern technologies, such as data virtualisation, can help FS organisations to get a handle on their data – regardless of where it is stored or what format it is in. Through a single logical view of all data across an organisation, it boosts visibility and real-time availability of data. This means that governance, security and compliance can be centralised, vastly improving control and removing the need for repeatedly moving and copying the data around the enterprise. This can have an immediate impact in terms of enabling FS organisations to avoid data proliferation and ‘shadow’ IT.

In addition to this, when a new regulation is put in place, data virtualisation provides a way to easily find and access that data, so FS organisations can respond – without having to worry about alternative versions of that data – and ensures that they remain compliant from the offset. This level of control can be reflected even down to the finest details. For example, it is possible to set up access to governance rules through which operators can easily select who has access to what information across the organisation. They can alter settings for sharing, removing silos, masking and filtering through defined, role-based data access. In terms of governance, this feature is essential, ensuring that only those who have the correct permissions to access sensitive information are able to do so.

Compliance is a requirement that will be there forever. In fact, its role is only likely to increase as law catches up with technological advancement and the regulatory landscape continues to change. For FS organisations, failure to meet the latest legal requirements could be devastating. The monetary fines – although substantial – come second to the potential reputation damage associated with non-compliance. It could be the difference between an organisation surviving and failing in today’s climate.

No one knows what is around the corner. Whilst some companies may think they are ahead of the compliance game today, that could all change with the introduction of a new regulation tomorrow. The best way to ensure future compliance is to get a handle on your data. By providing total visibility, data virtualisation is helping organisations to gain back control and win the war for compliance.

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TCI: A time of critical importance



TCI: A time of critical importance 2

By Fabrice Desnos, head of Northern Europe Region, Euler Hermes, the world’s leading trade credit insurer, outlines the importance of less publicised measures for the journey ahead.

After months of lockdown, Europe is shifting towards rebuilding economies and resuming trade. Amongst the multibillion-euro stimulus packages provided by governments to businesses to help them resume their engines of growth, the cooperation between the state and private sector trade credit insurance underwriters has perhaps missed the headlines. However, this cooperation will be vital when navigating the uncertain road ahead.

Covid-19 has created a global economic crisis of unprecedented scale and speed. Consequently, we’re experiencing unprecedented levels of support from national governments. Far-reaching fiscal intervention, job retention and business interruption loan schemes are providing a lifeline for businesses that have suffered reductions in turnovers to support national lockdowns.

However, it’s becoming clear the worst is still to come. The unintended consequence of government support measures is delaying the inevitable fallout in trade and commerce. Euler Hermes is already seeing increase in claims for late payments and expects this trend to accelerate as government support measures are progressively removed.

The Covid-19 crisis will have long lasting and sometimes irreversible effects on a number of sectors. It has accelerated transformations that were already underway and had radically changed the landscape for a number of businesses. This means we are seeing a growing number of “zombie” companies, currently under life support, but whose business models are no longer adapted for the post-crisis world. All factors which add up to what is best described as a corporate insolvency “time bomb”.

The effects of the crisis are already visible. In the second quarter of 2020, 147 large companies (those with a turnover above €50 million) failed; up from 77 in the first quarter, and compared to 163 for the whole of the first half of 2019. Retail, services, energy and automotive were the most impacted sectors this year, with the hotspots in retail and services in Western Europe and North America, energy in North America, and automotive in Western Europe

We expect this trend to accelerate and predict a +35% rise in corporate insolvencies globally by the end of 2021. European economies will be among the hardest hit. For example, Spain (+41%) and Italy (+27%) will see the most significant increases – alongside the UK (+43%), which will also feel the impact of Brexit – compared to France (+25%) or Germany (+12%).

Companies are restarting trade, often providing open credit to their clients. However, there can be no credit if there is no confidence. It is increasingly difficult for companies to identify which of their clients will emerge from the crisis from those that won’t, and whether or when they will be paid. In the immediate post-lockdown period, without visibility and confidence, the risk was that inter-company credit could evaporate, placing an additional liquidity strain on the companies that depend on it. This, in turn, would significantly put at risk the speed and extent of the economic recovery.

In recent months, Euler Hermes has co-operated with government agencies, trade associations and private sector trade credit insurance underwriters to create state support for intercompany trade, notably in France, Germany, Belgium, Denmark, the Netherlands and the UK. All with the same goal: to allow companies to trade with each other in confidence.

By providing additional reinsurance capacity to the trade credit insurers, governments help them continue to provide cover to their clients at pre-crisis levels.

The beneficiaries are the thousands of businesses – clients of credit insurers and their buyers – that depend upon intercompany trade as a source of financing. Over 70% of Euler Hermes policyholders are SMEs, which are the lifeblood of our economies and major providers of jobs. These agreements are not without costs or constraints for the insurers, but the industry has chosen to place the interests of its clients and of the economy ahead of other considerations, mindful of the important role credit insurance and inter-company trade will play in the recovery.

Taking the UK as an example, trade credit insurers provide cover for more than £171billion of intercompany transactions, covering 13,000 suppliers and 650,000 buyers. The government has put in place a temporary scheme of £10billion to enable trade credit insurers, including Euler Hermes, to continue supporting businesses at risk due to the impact of coronavirus. This landmark agreement represents an important alliance between the public and private sectors to support trade and prevent the domino effect that payment defaults can create within critical supply chains.

But, as with all of the other government support measures, these schemes will not exist in the long term. It is already time for credit insurers and their clients to plan ahead, and prepare for a new normal in which the level and cost of credit risk will be heightened and where identifying the right counterparts, diversifying and insuring credit risk will be of paramount importance for businesses.

Trade credit insurance plays an understated role in the economy but is critical to its health. In normal circumstances, it tends to go unnoticed because it is doing its job. Government support schemes helped maintain confidence between companies and their customers in the immediate aftermath of the crisis.

However, as government support measures are progressively removed, this crisis will have a lasting impact. Accelerating transformations, leading to an increasing number of company restructurings and, in all likelihood, increasing the level of credit risk. To succeed in the post-crisis environment, bbusinesses have to move fast from resilience to adaptation. They have to adopt bold measures to protect their businesses against future crises (or another wave of this pandemic), minimize risk, and drive future growth. By maintaining trust to trade, with or without government support, credit insurance will have an increasing role to play in this.

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What Does the FinCEN File Leak Tell Us?



What Does the FinCEN File Leak Tell Us? 3

By Ted Sausen, Subject Matter Expert, NICE Actimize

On September 20, 2020, just four days after the Financial Crimes Enforcement Network (FinCEN) issued a much-anticipated Advance Notice of Proposed Rulemaking, the financial industry was shaken and their stock prices saw significant declines when the markets opened on Monday. So what caused this? Buzzfeed News in cooperation with the International Consortium of Investigative Journalists (ICIJ) released what is now being tagged the FinCEN files. These files and summarized reports describe over 200,000 transactions with a total over $2 trillion USD that has been reported to FinCEN as being suspicious in nature from the time periods 1999 to 2017. Buzzfeed obtained over 2,100 Suspicious Activity Reports (SARs) and over 2,600 confidential documents financial institutions had filed with FinCEN over that span of time.

Similar such leaks have occurred previously, such as the Panama Papers in 2016 where over 11 million documents containing personal financial information on over 200,000 entities that belonged to a Panamanian law firm. This was followed up a year and a half later by the Paradise Papers in 2017. This leak contained even more documents and contained the names of more than 120,000 persons and entities. There are three factors that make the FinCEN Files leak significantly different than those mentioned. First, they are highly confidential documents leaked from a government agency. Secondly, they weren’t leaked from a single source. The leaked documents came from nearly 90 financial institutions facilitating financial transactions in more than 150 countries. Lastly, some high-profile names were released in this leak; however, the focus of this leak centered more around the transactions themselves and the financial institutions involved, not necessarily the names of individuals involved.

FinCEN Files and the Impact

What does this mean for the financial institutions? As mentioned above, many experienced a negative impact to their stocks. The next biggest impact is their reputation. Leaders of the highlighted institutions do not enjoy having potential shortcomings in their operations be exposed, nor do customers of those institutions appreciate seeing the institution managing their funds being published adversely in the media.

Where did the financial institutions go wrong? Based on the information, it is actually hard to say where they went wrong, or even ‘if’ they went wrong. Financial institutions are obligated to monitor transactional activity, both inbound and outbound, for suspicious or unusual behavior, especially those that could appear to be illicit activities related to money laundering. If such behavior is identified, the financial institution is required to complete a Suspicious Activity Report, or a SAR, and file it with FinCEN. The SAR contains all relevant information such as the parties involved, transaction(s), account(s), and details describing why the activity is deemed to be suspicious. In some cases, financial institutions will file a SAR if there is no direct suspicion; however, there also was not a logical explanation found either.

So what deems certain activities to be suspicious and how do financial institutions detect them? Most financial institutions have sophisticated solutions in place that monitor transactions over a period of time, and determine typical behavioral patterns for that client, and that client compared to their peers. If any activity falls disproportionately beyond those norms, the financial institution is notified, and an investigation is conducted. Because of the nature of this detection, incorporating multiple transactions, and comparing it to historical “norms”, it is very difficult to stop a transaction related to money laundering real-time. It is not uncommon for a transaction or series of transactions to occur and later be identified as suspicious, and a SAR is filed after the transaction has been completed.

FinCEN Files: Who’s at Fault?

Going back to my original question, was there any wrong doing? In this case, they were doing exactly what they were required to do. When suspicion was identified, SARs were filed. There are two things that are important to note. Suspicion does not equate to guilt, and individual financial institutions have a very limited view as to the overall flow of funds. They have visibility of where funds are coming from, or where they are going to; however, they don’t have an overall picture of the original source, or the final destination. The area where financial institutions may have fault is if multiple suspicions or probable guilt is found, but they fail to take appropriate action. According to Buzzfeed News, instances of transactions to or from sanctioned parties occurred, and known suspicious activity was allowed to continue after it was discovered.

Moving Forward

How do we do better? First and foremost, FinCEN needs to identify the source of the leak and fix it immediately. This is very sensitive data. Even within a financial institution, this information is only exposed to individuals with a high-level clearance on a need-to-know basis. This leak may result in relationship strains with some of the banks’ customers. Some people already have a fear of being watched or tracked, and releasing publicly that all these reports are being filed from financial institutions to the federal government won’t make that any better – especially if their financial institution was highlighted as one of those filing the most reports. Next, there has been more discussion around real-time AML. Many experts are still working on defining what that truly means, especially when some activities deal with multiple transactions over a period of time; however, there is definitely a place for certain money laundering transactions to be held in real time.

Lastly, the ability to share information between financial institutions more easily will go a long way in fighting financial crime overall. For those of you who are AML professionals, you may be thinking we already have such a mechanism in place with 314b. However, the feedback I have received is that it does not do an adequate job. It’s voluntary and getting responses to requests can be a challenge. Financial institutions need a consortium to effectively communicate with each other, while being able to exchange critical data needed for financial institutions to see the complete picture of financial transactions and all associated activities. That, combined with some type of feedback loop from law enforcement indicating which SARs are “useful” versus which are either “inadequate” or “unnecessary” will allow institutions to focus on those where criminal activity is really occurring.

We will continue to post updates as we learn more.

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