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).