Brazilian construction group Odebrecht adopted corruption as a “business model,” according to superstar judge Sergio Moro, who is heading the wide-ranging Carwash corruption investigation in the country. For a long time, the results were so good that the group apparently decided to export the model around the world—investing billions of dollars in the process. But as it did, it failed to recognize just how much it would provide a catalyst for law enforcement agencies to work across borders and to spur a global answer to global corruption problems. Odebrecht might be one of the great compliance failures of our time but, ironically, it might also help create much-improved compliance, anti-corruption, and law enforcement efforts in its wake.

As a result of plea bargain deals signed by the company and dozens of its executives with Brazilian, U.S., and Swiss authorities, the extraordinary extent of Odebrecht’s international bribery payments is coming to light. Executives have told investigators that Odebrecht paid as much as $3.39 billion in bribes, in Brazil and abroad, between 2006 and 2014. The sophistication of the company’s bribery scheme was such that a dedicated unit, which received the very technocratic name of Department of Structured Operations, was created to guarantee the efficiency of payments. The unit bought a bank in Antigua to channel the bribery money and to fuel money into the system, and artificial accounting losses were created by derivative transactions and by the misrepresentation of revenues in projects developed in countries with loose banking supervision. If the system had a hint of financial mastery about it, that was possibly not a surprise. Marcelo Odebrecht, the president of the group who allegedly controlled the bribery scheme, has an MBA from a Swiss business school and used to be a young star at the World Economic Forum in Davos, an organization that likes to promote business innovation.

The crumbling of Odebrecht’s international bribery network has caused plenty of embarrassment for politicians and business partners in countries like Argentina, Peru, and Colombia, where even current presidents have been hit by the flak. And it has required Brazilian prosecutors to sharpen their cooperation skills in order to garner the help of their peers in dozens of other countries reached by the tentacles of Odebrecht and other companies involved in the scandal. The Brazilian prosecutor’s office has exchanged information about the investigations with no less than 42 countries. By the end of February, Brazil had sent 130 requests of cooperation from 33 of them and 24 have demanded to learn more about the Carwash operation in order to feed their own domestic investigations. The group includes plenty of Latin American countries, but also the United States, Canada, China, several EU members, and a full roster of tax haven jurisdictions.

The amount of data to be shared is such that public prosecutors from 11 Latin American nations met in Brasilia in February to agree on a working strategy to deal with the case. The meeting took place after a Brooklyn court made public the details of the settlement that Odebrecht and its subsidiary Braskem signed with the American courts to end investigations in the country.

“Criminals that acted locally now work on a global basis, and this development has required that public prosecutors follow the same road,” said Vladimir Aras, who heads the international cooperation unit at Brazil’s Public Prosecutors Office. “International cooperation has therefore gained relevance in national agendas.” The hope of investigators is that this kind of initiative will cement cooperation between prosecution teams and provide another boost to anti-corruption strategies, which continue to meet strong opposition by political and business groups, and sometimes even from the courts, in many Latin American countries.

If a lesson is to be learned from the Odebrecht case, it is that bribery may not disappear from public and private relationships in Latin America, but the risk of being caught, and its consequences, is more severe than ever before.

In fact, transnational cooperation in corruption investigations has been a new development in a region where authorities have for a long time refrained from working too closely with their neighbors due to a strong sense of national sovereignty, but also to less justifiable reasons. The revelations already disclosed by the Odebrecht plea bargains have provided a further boost to a process under way in the past decade or two where public prosecutors have made use of expanded powers and surfed the support of voters, who voice discontent on social media at every opportunity. “The penetration of the internet has helped to increase the perception of the problem of corruption by society and to create an environment that is adequate to the employment of the tools that the law provides,” Aras said.

In recent years, the public has in fact watched scenes that Latin Americans once believed they would never see in the course of their lives. In Brazil, two generations of moguls who boast Odebrecht’s powerful name—current president Marcelo and his antecessor and father, Emilio—have gone to jail, and a former Brazilian president, Luiz Inácio Lula da Silva, could follow them, partly due to his relationship with the firm. Several other politicians and business leaders are enduring jail time as well. Colombian president and Nobel Peace Prize Winner Juan Manuel Santos has faced accusations that Odebrecht paid part of his campaign expenses in 2010, although he has pled ignorance of the fact. A number of Colombian businesspeople and politicians have been arrested for Odebrecht-related revelations, and the confessions by the firm’s executives have even implicated candidates that opposed Santos in the latest election, as well as the far-left guerrilla FARC.

In Ecuador, suspicions that members of the government led by president Rafael Correa were mentioned in Odebrecht’s plea bargain deals have helped to turn what should have been a shoo-in election to choose his successor into a competitive battle that the opposition may actually win. The Argentinian president, Mauricio Macri, has had to fend off accusations that a cousin and members of his government were in Odebrecht’s illegal pay roll, and Peruvian officials under three different presidents have allegedly received $29 million in bribes paid by the insatiable Brazilian group. The city of Lima is even discussing whether it should put down a replica of Rio’s Christ Redeemer that was built in 2011 in one of its neighborhoods, after it emerged that the replica had been funded by Odebrecht as a gift to politicians. The cases go on and on, including countries such as Mexico, the Dominican Republic, Angola, and others in the row of places mentioned in the confessions.

The whole case has shown how entangled business and politics can become in the region and also that it is impossible for one country’s authorities to fight the problem without the help of their peers from abroad. “International cooperation by Brazilian investigators has increased in recent years, and that is due to structural progress,” said Marcos Tourinho, a lecturer of International Relations at FGV, a business school. “It does not depend on individuals, as Brazil’s prosecutors office has plenty of independence.”

Cooperation regarding Odebrecht and the Carwash operation is picking up even outside of Brazil's already well-developed investigations. In the end of March, prosecutors from Colombia and Ecuador announced that they would trigger joint investigations on Odebrecht and its Spanish rival Acciona, who are suspected of having split infrastructure projects in both countries, something that Acciona has denied. (The company, along with other Spanish construction firms, is under investigation by anti-corruption officials in Spain for similar allegations regarding their Latin American operations). Even transnational punishments have gotten into the agenda. In a recent interview to Peruvian newspaper La Republica, Augusto Nardes, the head of TCU, Brazil’s auditing court, said that plans are being discussed to make sure that a company that has been caught paying bribes in one Latin American country becomes ineligible to contract with governments in other parts of the region.

The cooperation has also been fruitful with American prosecutors, who have shown great interest in the Carwash investigations, which have led to one of the largest FCPA-related settlements already signed by the SEC and the DoJ. “I have seen Brazilian prosecutors reach DoJ members by phone immediately for conversations,” said Isabel Franco, a lawyer at the Kouri Lopes law office in São Paulo, who has been picked by the American authorities to be one of the monitors of Braskem’s agreement-imposed compliance efforts. “They are in contact all the time.”

Franco noted that formal channels of international cooperation were reinforced in Brazil by the introduction of an Anti-Money Laundering Law in 2012 and an FCPA-like anti-corruption legislation in 2014, as well as adherence by the country to relevant international treaties. And Aras stressed prosecutors have strengthened their intelligence networks by which they share information even before formal requests of cooperation are lodged by governments. “Europe’s Carin and South America’s RRAG have been key to track and recover assets in the Carwash investigations,” he said, referring to two regional inter-agency networks specialized in financial crimes. “This is of essence to counter the complexity of criminal activities today.”

Aras and Franco also highlighted that one of the main consequences of all these developments is that Brazilian companies will be required to implement effective compliance mechanisms, not only in their domestic operations, where they are still incipient, but also abroad. “The basic goal is to make companies compliant with national and international legislation,” Franco said. “Companies must invest in effective programmes for both prevention and remediation of corruption cases.”

In the meantime, governments are trying to soothe to the popular tsunami created by the Odebrecht revelations. In Brazil, the company has had payments by the government retained and its participation in projects has been jeopardized while a leniency agreement with public prosecutors is not fully approved by other government bodies. BNDES, Brazil’s development bank, is also holding funding for Odebrecht’s international projects. In Argentina, where it is accused of paying $35 million in bribes, the company has started negotiations with the government to try to minimize any punishments. In Peru, its first international market, the government has blocked payments to Odebrecht for projects that the company is building in the country. A contract to build an oil pipeline in Peru has been revoked, as well as a road concession in Colombia. Odebrecht is also looking for buyers for assets in Brazil and abroad in a strategy to raise much-needed funds to recover its embattled finances. And the company, along with its subsidiary Braskem, has agreed to pay $3.5 billion in penalties to settle its case with public prosecutors in Brazil, the United States, and Switzerland.

If a lesson is to be learned from the Odebrecht case, it is that bribery may not disappear from public and private relationships in Latin America, but the risk of being caught, and its consequences, is more severe than ever before.

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