Dutch oil-services company SBM Offshore and its wholly owned U.S. subsidiary, SBM Offshore USA, have agreed to pay $238 million to settle allegations that they engaged in a widespread, systematic scheme to bribe government officials in more than five countries. The DOJ had previously declined to prosecute the company but reopened its investigation when new facts came to light. SBM previously settled with Dutch authorities and has been attempting to settle with Brazilian authorities for some time. We look at the company’s corrupt commission payment scheme and the factors that went into its significant penalty discount. See “Petrobras and Unaoil Investigations Collide in Individual Prosecutions in the U.S. and U.K.” (Nov. 29, 2017).