In a rare case imposing liability on a parent issuer for poor internal controls of a minority-owned subsidiary, the Italian oil and gas giant Eni S.p.A. has resolved FCPA allegations with the SEC for $24.5 million. The amount of the settlement “reflects the very light nature of the challenge and the exclusion of any corrupt practice,” Eni’s senior executive vice president of legal affairs told the Anti-Corruption Report. The oil industry is one rife with corruption risk and Eni is no stranger to FCPA actions – it settled SEC charges in 2010 and is currently defending itself in Milan against charges that it, along with Royal Dutch Shell Plc, bribed Nigerian officials in the purchase of a license to an undeveloped deepwater block in 2011. We detail the settlement and its implications. See “Samsung Heavy Industries Resolves Petrobras-Related FCPA Charges With a Split Fine” (Dec. 11, 2019).