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Issues To Consider From The Honeywell Enforcement Action

By on December 22, 2022 in Compliance, Gray Cloud, Honeywell, Statute of Limitations
Issues

As highlighted in this post, Honeywell recently resolved a net $82 million Foreign Corrupt Practices Act enforcement action concerning conduct in Brazil and Algeria.

This post highlights additional issues to consider.

Timeline

As highlighted in this prior post, in mid-2019 Honeywell disclosed that it was cooperating with the DOJ/SEC and Brazilian law enforcement investigations relating to its use of third parties in relation to Petrobras (Brazil) business as well as a matter involving a foreign subsidiary’s prior engagement of Unaoil in Algeria.

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Honeywell Resolves Net $82 Million FCPA Enforcement Action Concerning Conduct In Brazil And Algeria

By on December 20, 2022 in 2022 Enforcement Action, Algeria, Brazil, DOJ Enforcement Action, Honeywell, Oil and Gas Industry, SEC Enforcement Action, Third Parties, Unaoil
Honeywell

Turns out, things were not so well at Honeywell.

As highlighted in this prior post, in mid-2019 Honeywell disclosed that it was cooperating with the DOJ/SEC and Brazilian law enforcement investigations relating to its use of third parties in relation to Petrobras (Brazil) business as well as a matter involving a foreign subsidiary’s prior engagement of Unaoil in Algeria.

Yesterday, the DOJ and SEC announced (see here and here) a parallel Foreign Corrupt Practices Act enforcement action against Honeywell UOP (a U.S. based subsidiary of Honeywell International) and Honeywell International.

The net $82 million enforcement action involved a DOJ component (net $39.6 million) and an SEC component (net $42.4 million).

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Scrutiny Alerts And Updates

By on October 25, 2021 in Baker Hughes, Honeywell
scrutiny alert

Honeywell

As highlighted in this prior post, in mid-2019 Honeywell disclosed that it was cooperating with DOJ/SEC and Brazilian law enforcement investigations relating to its use of third parties in relation to Petrobras business as well as a matter involving a foreign subsidiary’s prior engagement of Unaoil in Algeria.

As highlighted in this prior post, in July 2021 Honeywell disclosed:

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Scrutiny Alerts

By on July 23, 2021 in China, DeepGreen Metals Inc, General Electric, Honeywell, Medical Device Industry, Philips, Siemens
scrutiny alert

Honeywell

As highlighted in this prior post, in mid-2019 Honeywell disclosed that it was cooperating with the DOJ/SEC and Brazilian law enforcement investigations relating to its use of third parties in relation to Petrobras business as well as a matter involving a foreign subsidiary’s prior engagement of Unaoil in Algeria.

Honeywell recently disclosed: “We have begun discussions with the authorities with respect to a potential resolution of these matters. As the discussions are ongoing, there can be no assurance as to whether we will reach a resolution with such authorities or as to the potential timing, terms, or collateral consequences of any such resolution. As a result, we cannot predict the outcome of these matters, the potential impact on the Company, or a reasonable estimate of losses or range of losses at this time.”

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