In a resolution that may be a win-win for both the government and the defendant, Honeywell has entered into a three-year deferred prosecution agreement with the DOJ to resolve allegations that the company conspired to violate the FCPA by offering a $4 million bribe to a former Petrobras executive. In all, Honeywell agreed to pay more than $160 million to resolve parallel global investigations. In the first part of this article series analyzing the resolution, we discussed the bribery scheme, what Honeywell did right, and the significance of the omission of a monitor from the resolution. In this second part, we discuss the certification requirements of the settlement, the effect of the size of the company on compliance and the international cooperation in the case. See “2022 FCPA Year in Review: Clawbacks, Messaging Apps and More Enforcement to Come” (Dec. 21. 2022).