The FCPA settlement with Samsung Heavy Industries (SHI), a Samsung Group subsidiary dedicated to storage vessels and offshore oil platforms, is the latest in a long line of Petrobras-related corruption scandals. On November 22, 2019, SHI agreed to a deferred prosecution agreement
that requires it to pay $75.5 million in total criminal penalties – half to the U.S. and half to Brazil – to resolve the charges it paid Brazilian agents $20 million from 2007 to 2013 to bribe Petrobras executives to facilitate the sale of an offshore drilling ship. SHI only received partial cooperation credit because of delays the DOJ says it caused, but it did escape a compliance monitor. We review the case and its implications. See “How Companies Can Respond to the Boom in FCPA Enforcement Fueled by International Cooperation
” (Oct. 30, 2019).