Petrobras, which has been at the center of a swirling storm of anti-corruption investigations in Brazil for years, has found a measure of repose, at least with regards to U.S. enforcers. In a historic, multilateral settlement, the company has agreed to pay billions in disgorgement, penalties, fines and a civil settlement to the SEC, DOJ, Brazilian authorities and shareholder plaintiffs. In this article we take a look at the surprisingly skimpy fact patterns in the DOJ and SEC papers, as well as the terms of the settlement. Future articles will touch on the uniqueness of entering a settlement with a state-controlled entity and lessons from Petrobras’ extensive remediation efforts. See “The View From a Brazilian Prosecutor” (Jan. 10, 2018).