A Clean Slate? Analyzing SBM’s Latest Brazilian Settlement

Despite SBM’s recent leniency agreement with multiple Brazilian government agencies, it is unclear whether the settlement will be the final adjudication of SBM’s legal issues in Brazil. Uncertainty looms over Brazilian leniency agreements, Eloy Rizzo and Victoria Arcos of KLA – Koury Lopes Advogados explain in a guest article, because jurisdiction is spread over many government bodies and there may be liability for related violations. They detail SBM’s legal travails in Brazil and provide key compliance takeaways. See “SBM Offshore Reaches FCPA Settlement After a Reopened DOJ Investigation” (Dec. 13, 2017).

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