Brooge Energy Ltd

Brooge Energy Limited operates a midstream oil storage and service business, strategically located outside the Strait of Hormuz adjacent to the Port of Fujairah in the United Arab Emirates. With the opening of its Phase II facility in 2021, the company became the second largest independent oil storage operator in the region, providing essential infrastructure for the global fossil fuel trade.

The company’s core business is fundamentally tied to fossil fuels, but its exclusion is primarily driven by severe regulatory and financial misconduct. In December 2023, the SEC charged Brooge Energy and former executives with fraud, finding that the company created false invoices to inflate revenues from its oil facilities by over $70 million. This massive fabrication of financial records led to a securities class action lawsuit and ongoing Nasdaq compliance issues. The SEC order details a scheme involving collusion to fabricate audit evidence, a fundamental breach of market integrity that calls into question the company’s governance and operational reporting.