Vantage Drilling International has settled charges with the SEC that it failed to implement appropriate internal controls in its transactions with an independent director and a Brazilian agent. The SEC alleged that the agent and director paid bribes to a Petrobras official in 2009 and 2010 – bribes that were initially brought to light by Brazilian investigators. The DOJ declined to prosecute in 2017 and the SEC agreed to a reduced fine in light of Vantage’s financial condition, and perhaps other factors. We analyze the case and the compliance takeaways. See our three-part series on the Petrobras settlement: “Deal With SEC and DOJ to Resolve Allegations of Systemic Bribery” (Oct. 17, 2018); “State-Owned Entity, Victim and Perpetrator” (Oct. 31, 2018); and “Lessons on Preventing Top-Down Corruption” (Nov. 14, 2018).