Petrobras Finally Inks Deal With SEC and DOJ to Resolve Allegations of Systemic Bribery

Petrobras, which has been at the center of a swirling storm of anti-corruption investigations in Brazil for years, found a measure of repose, at least with regards to U.S. enforcers in its historic, multilateral settlement, In 2018, the company has agreed to pay billions in disgorgement, penalties, fines and a civil settlement to the SEC, DOJ, Brazilian authorities and shareholder plaintiffs. In the first article in our series, we took a look at the surprisingly skimpy fact patterns in the DOJ and SEC papers, as well as the terms of the settlement. In the second article, we explored how and Petrobras’ various roles make the settlement a singular beast that shows how U.S. enforcers can use their discretion to come to just outcomes. And, in the final article, we discussed lessons that Petrobras’ extensive remediation holds for other companies on how to fight corruption in the upper echelons of their corporate structure.

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