Petrobras, the state-owned oil company at the heart of the biggest corruption scandal in history, recently settled with U.S. and Brazilian enforcers. In addition to being one of the largest anti-corruption resolutions of all time, the SEC and DOJ settlements are far from typical. Petrobras is several things at once: victim and perpetrator; bribe payer and bribe taker; sovereign entity and commercial business. These dichotomies make the settlement a singular beast that shows how U.S. enforcers can use their discretion to come to just outcomes. See “Petrobras Finally Inks Deal With SEC and DOJ to Resolve Allegations of Systemic Bribery” (Oct. 17, 2018).