Weatherford is well known in the compliance community for its 2013 FCPA settlement where it agreed to the then-ninth largest FCPA fine of all-time. Additionally, one of its subsidiaries, pled guilty to violating the anti-bribery provisions of the FCPA. The total amount of fines and penalties for the FCPA violations was $152.6 million. The company was also hit with another $100 million in fines and penalties for trade sanctions bringing its total amount paid to $252.6 million.

The company entered into a three-year DPA, which included an external monitor. However, the term of the monitor was not the entire length of the three-year DPA; the term of the monitor was only 18 months. The monitor’s primary function was to assess the company’s compliance with the terms of the DPA and report the results to the Justice Department at least twice during the terms of the monitorship. The DPA also provided that the term of the external monitor could be extended by the DoJ.

Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in...