In the SEC’s first FCPA settlement of the Trump administration, Halliburton has agreed to pay disgorgement and penalties of more than $29 million for books and records and internal controls violations related to a local partner in Angola. The case may signal that SEC enforcement under Jay Clayton will continue in a similar vein as it did under the Obama administration. A former vice president at the company who circumvented numerous internal controls to close a deal settled individually as well. We spoke with a number of anti-corruption experts to digest the case and find out what companies can do to avoid similar problems. See “First FCPA Actions Under Sessions’ DOJ Are Declinations With Disgorgement” (Jul. 19, 2017).