Issues To Consider From The Honeywell Enforcement Action
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.
Honeywell Resolves Net $82 Million FCPA Enforcement Action Concerning Conduct In Brazil And Algeria
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).
Scrutiny Updates
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.
In its most recent quarterly filing disclosed:
Scrutiny Alerts And Updates
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:
Scrutiny Alerts
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.”