While it is unsurprising that the years-long Operation Car Wash investigation in Brazil is resulting in big penalties, the means by which the bribes were paid by Brazilian holding company Odebrecht and its petrochemical subsidiary Braskem are a bit beyond the pale. In this first article in a two-part series dissecting Odebrecht and Braskem’s $3.5 billion-plus historic settlements with U.S., Brazilian and Swiss authorities, we look at the bribes the companies paid and how Odebrecht’s so-called “department of bribes” made those corrupt payments possible. In the second article, we will look at the role international cooperation played in both the investigations and the terms of the settlement. See “Embraer Uses Sleight-of-Hand Payments to Third-Party Agents to Sell Planes Around the World, Landing It More Than $200M in U.S. Fines” (Nov. 9, 2016).