After holding the record for the largest corruption related fine, $2.6bn paid to three countries, for a short few months, the Brazilian construction giant Odebrecht was overtaken by the Brazilian meat processing giant J&F Investments which clocked in with a $3.2bn fine in April. The entire amount was payable to the Brazilian government and J&F may face additional penalties from other countries. But Odebrecht is not out of the woods yet, as it may face additional penalties for its Americas-wide institutionalized program of bribery and corruption.

Odebrecht is trying to salvage itself from the ruins of its corrupt run as one of the leading construction companies in the Americas. In 2015, it saw revenues exceed $40bn, but now that has sorely dropped. One of the reasons is the company has been cut off from its prime source of credit, the Brazilian state development bank of BNDES, which is reported to be refusing to finance the company’s projects. Yet, the company is taking steps to move forward.

The company has brought in not one but two external monitors installed in the corporate headquarters. These monitors have worked to create the backbone of a compliance program with both policies/procedures and structural changes such as the creation of a CCO position reporting directly to the board of directors. The company has been forced to consolidate down its business size to become more manageable from a compliance perspective. Most importantly, the Odebrecht family is stepping back from its iron-fisted control of the company. Family members will no longer have senior executive roles in the organization. They will also be selling off interests in certain company assets.

The only other prior example of a company that had a fine close to the size of Odebrecht was the German company Siemens. Siemens, however, had a much more core base of business that was not generated from bribery and corruption. The same may not be true of Odebrecht. Additionally, the credit squeeze is forcing the company to now compete in the international financing market and not obtain the sweetheart deals it previously had access to through BNDES. It will be interesting to see the fate of Odebrecht going forward.