As part of what appears to be a sweep of commodities trading firms, the DOJ recently announced one of its largest settlements in the last few years. Swiss-based Gunvor S.A. has agreed to pay over $661 million to resolve an investigation into FCPA violations related to its dealings with Ecuador’s state-owned and -controlled oil company, Petroecuador. The company appears to have paid a higher penalty due to its previous anti-corruption issues and its lackluster cooperation, but it still managed to avoid a compliance monitor by engaging in significant remediation. The Anti-Corruption Report spoke with experts in the field to tease out the lessons from the case. See “SAP’s $220‑Million Settlement Offers Clues on Compliance Expectations” (Feb. 14, 2024).