Salvador Dahan on the Journey of Petrobras
This Week in FCPA-Episode 122, the Kavanaugh, Rosenstein and 100+ Wins edition
D&O in Brazil and Latin America
FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras
Month in a Minute: July and August 2025 - Hughes Hubbard’s anti-corruption “Month in a Minute” offers a quick snapshot of the key foreign corruption-related developments from the prior month. This special Summer Recap...more
Trafigura’s bribery scheme resembles the same schemes implemented by its significant competitors — Vitol, Glencore, Gunvor. At the core of the conduct, Petrobras and Brazilian government officials collected bribes in...more
We conclude our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international commodity trading company with its primary operations in...more
We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm trading firm G Trafigura Beheer B.V. (Trafigura), an international commodity trading company with its primary...more
We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international commodity trading company with its primary operations in...more
Overview - A recent spate of cases on both sides of the Atlantic in 2023 show that criminal enforcement and asset recovery proceedings stemming from the iconic Brazilian anti-corruption investigation, Operation “Car Wash”...more
In its first enforcement action of 2023, the Justice Department charged a Connecticut man and a foreign national with FCPA bribery and money laundering charges stemming from a bribery scheme to secure contracts with Petrobras...more
We all know and hear about third-party risks – over and over again. Despite this recurring theme, organizations continue to pay the price for failing to address third-party issues. It does not take a rocket scientist to...more
FCPA settlement actions often underscore specific compliance risks for legal and compliance professionals. If there ever was a case where third-party risks were bungled, and even intentionally embraced, the Foster Wheeler...more
The Justice Department is coming to the close of a record FCPA enforcement year despite the disruptions caused by the pandemic. The Vitol case also represents the first parallel prosecution involving the Commodities Futures...more
The Justice Department continues to produce FCPA resolutions in a record year for enforcement. The latest, and perhaps the beginning of several end-of-year and end of the Trump Administration resolutions, is DOJ’s settlement...more
The UK Serious Fraud Office (the “SFO”) has reached a £1.2 million civil recovery settlement with Julio Faerman, a Brazilian national linked to the sprawling “Operation Car Wash” investigation involving the Brazilian...more
Last week, another Foreign Corrupt Practices Act (FCPA) case was resolved. It involved Samsung Heavy Industries Company Limited (SHI), a South Korea-based engineering company that provides shipbuilding, offshore platform...more
Samsung’s recent FCPA settlement with the Justice Department capped yet another example of a company involved in bribing Petrobas in Brazil for valuable contracts. The scope of the bribery scheme was focused on a contingent...more
Samsung Heavy Industries agreed with the Justice Department to pay $75 million to settle FCPA charges. Under a three-year deferred prosecution agreement (DPA), Samsung agreed to filing of a criminal information in the Eastern...more
• Four years ago, Brazilian authorities began Operation Car Wash, a wide-ranging and still ongoing corruption and money laundering investigation that has spanned 11 countries. • The fallout continues with a recent U.S....more
This blog post concludes my multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. Today we consider the stunning result achieved by Petrobras –...more
When it comes to a poster-child for corrupt organizations, there is very little competition that can eclipse Petrobas, the Brazilian state-owned oil and gas company. ...more
This blog post will begin a multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. The action was a stunning reminder of the costs of endemic...more
Keeping ahead of global anti-corruption trends is critical in today’s business markets. The Dorsey Anti-Corruption Digest, which puts global trends at your fingertips, puts you ahead. The deep experience of the Dorsey...more
On this date in 2008 George Carlin died. If you grew up in the late 1960s or early 1970s and you had anti-parental or anti-establishment inklings, which of course all teenagers do, you knew about George Carlin. In the early...more
When does bribery and corruption move from a business issue to a political issue to a national issue? Why should US companies be held to the gold standard of anti-corruption laws? Should the US government even care if US...more
In this episode, Compliance Week Editor-in-Chief Matt Kelly and I discuss the Avon and Alstom FCPA enforcement actions and then take a look at the ongoing Petrobras corruption scandal and what it means for Brazil. ...more