The Odebrecht global corruption enforcement action literally shook worldwide anti-corruption enforcement with its breadth, depth, and scope. The range of penalties from between $4.5bn to $2.6bn was one for the record books. The split of the fines and penalties between three countries: with 10 percent going to both the United States and Switzerland and the lion’s share of 80 percent going to Brazil was also unprecedented. Yet even with these shocks, the resulting tremors from the investigation and enforcement action may well continue for many years, most particularly in Latin America.
