J&F Investimentos’ FCPA Settlement Sheds Light on DOJ Policies and Acquisition Integration

The DOJ recently announced that Brazilian investment company J&F Investimentos S.A., owned by Joesley Batista and Wesley Batista, pleaded guilty to one count of conspiracy to violate the anti-bribery provisions of the FCPA and will pay more than $256 million to resolve the DOJ’s investigation. The Batista siblings, as well as J&F and its subsidiary JBS S.A., a meat producer, also agreed to pay almost $27 million to resolve the SEC’s allegations associated with a bribery scheme engaged in to ease JBS’s 2009 acquisition of Pilgrim’s Pride Corporation. The settlement – coming after the company’s $3.2‑billion Brazilian anti-bribery resolution – illustrates how business-friendly recent DOJ policies can be and highlights the continuing necessity of M&A due diligence and integration. See “J&F Investimentos’ Record-Breaking Fine Highlights Brazil’s Commitment to Fighting Corruption” (Jun. 21, 2017).

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