The Odebrecht and Braskem FCPA enforcement actions were not only stunners for the amounts involved but also as they portend a new trend in the global fight against bribery and corruption. The amount of the fines and penalties have a range from between $4.5bn to $2.6bn which is unusual in and of itself. However the amount payable to the US Treasury based on this fine has been estimated to be as low as $420 million but could go higher, if Odebrecht is found to have an ability to pay.
