As highlighted here, in September 2018 Petrobras (a Brazilian state-owned and state-controlled energy company) entered into agreements with U.S. and Brazilian authorities “in connection with Petrobras’s role in facilitating payments to politicians and political parties in Brazil, as well as a related Brazilian investigation.”
After various credits and deductions for a related law enforcement action in Brazil, the net FCPA settlement was approximately $170 million ($85.3 million DOJ, $85.3 million SEC).
The DOJ action was resolved through a three year non-prosecution agreement pursuant to which Petrobras, among other things, committed to continue to enhance its compliance program and internal controls, including ensuring that its compliance program satisfied the minimum elements set forth in an attachment to the NPA.
Petrobras recently announced that it has “concluded the obligations” set forth in the NPA.
