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Update on the Petrobras Corruption Scandal

Tom Fox | October 7, 2015

While we may have reached a tipping point on enforcement of anti-corruption laws such as the Foreign Corrupt Practices Act over the past 30 days, some huge ongoing anti-corruption enforcement actions are still out there. One only need to consider Walmart, GlaxoSmithKline, or Petrobras to realize some of the biggest settlements of all time are still coming down the pike sooner or later.

About this time last year, I thought that Petrobras would be the world’s largest corruption scandal—not only for the role the company played in Brazil, but also as one of the world’s giant oil and gas companies. Petrobras had operations or contracts with companies across the globe, and the reach of endemic corruption through these contractual relationships appeared to be simply stunning. Of course it turned out that Petrobras’ direct contractors and its approved sub-contractors were often in on the bribery scheme as well.

U.S.- based companies that conducted business in Brazil or with...

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