The introduction of leniency agreements between companies accused of corruption and Brazilian enforcement authorities was a major step forward in the fight against corruption in Brazil. However, a patchwork of anti-corruption laws has created a tangle of overlapping authority to settle corruption issues with companies, leaving many uneasy about their ability to find true repose in a negotiated resolution. In a guest article, Eloy Rizzo, a partner at Demarest Advogados, and associate Victoria Arcos explain how several Brazilian government agencies have come to an agreement on a framework for approaching leniency agreement negotiations, but with a key government agency withholding its signature from the agreement, the value of the framework is left in doubt. See “A Clean Slate? Analyzing SBM’s Latest Brazilian Settlement” (Dec. 13, 2017).