While much about the Operation Car Wash corruption scandal in Brazil is a confusing jumble, one thing is plainly clear – corruption permeated the company from the highest levels all the way down and any internal controls were inadequate to prevent that corruption. In its settlement with the SEC and DOJ, the state-owned oil company agreed to make some serious changes to how it approaches compliance, with a focus on preventing political interference and corruption from the top down. Those changes offer lessons for other companies in how to fight corruption at the upper echelons of their corporate structure. See “Petrobras Finally Inks Deal With SEC and DOJ to Resolve Allegations of Systemic Bribery” (Oct. 17, 2018); and “State-Owned Entity, Victim and Perpetrator: The Special Case of Petrobras” (Oct. 31, 2018).