The Petrobras scandal has been roiling Brazil for several years now, resulting in numerous prosecutions in the country as well as global settlements including Odebrecht and Braskem. The Unaoil scandal broke in March 2016 when it was reported that Unaoil had been bribing foreign officials to secure government contracts in the Middle East, Africa and Central Asia on behalf of its clients. Now four different individuals with ties to oil-services company SBM Offshore are facing criminal charges in two different countries for conduct related to both scandals. According to Kelly Kramer, a partner at Mayer Brown, the cases show that the DOJ “remains committed to prosecuting individuals in FCPA cases.” Indeed, Dan Fetterman, a partner at Kasowitz, said the charges show that the DOJ “will not hesitate to prosecute high-level executives who ‘consciously avoid’ learning that their conduct is or may be part of a corrupt scheme.” But will the company also be held liable? See “Regional Risk Spotlight: Giovanni Falcetta of TozziniFreire Talks Anti-Corruption in Brazil Beyond the Petrobras Scandal” (Mar. 23, 2016).