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.