Luxembourg-based steel pipe manufacturer Tenaris has agreed to pay the SEC more than $78 million to resolve charges relating to the payment by its Brazilian subsidiary of approximately $10.4 million in bribes to a Brazilian government official between 2008 and 2013. This follows a 2011 FCPA settlement for the company with the DOJ and SEC. This time, the DOJ has indicated that it does not intend to pursue charges. We analyze the settlement with insight from practitioners. See “Stericycle Settlement Offers Clues on the Monaco Memo in Practice
” (May 11, 2022).