On December 21, 2016, Brazilian construction conglomerate Odebrecht S.A. and its affiliate Braskem S.A. pled guilty to conspiracy to violate the FCPA for a scheme to bribe government officials, primarily in Brazil. In the largest foreign bribery case in history, Odebrecht and Braskem agreed to pay at least $3.5 billion to authorities in the United States, Brazil, and Switzerland. Odebrecht paid over $700 million in bribes to government officials and political parties in twelve countries, primarily in Brazil, but also in Venezuela, the Dominican Republic and Panama, among others. Nearly half of the corrupt payments were made to officials in Brazil, including executives and employees of Petroleo Brasileiro S.A. (“Petrobras”), Brazil’s state-controlled oil company. Odebrecht created a specialized division used to conceal the company’s bribery through off-book communications and payment systems, ultimately funneling the bribes through offshore entities. Braskem, a petrochemical company controlled by Odebrecht also used Odebrecht’s off-book system to pay bribes to Brazilian politicians. Braskem also settled a civil case brought by the SEC in the U.S. District Court for the District of Columbia. Read more about this resolution in our client alert. U.S. v. Odebrecht S.A., No. 16-CR-643 (E.D.N.Y.); U.S. v. Braskem S.A., No. 16-CR-644 (E.D.N.Y.) DOJ Press Release
