As part of Petrobras’ global settlement with the SEC, DOJ, Brazilian prosecutors and shareholders, the state-owned oil company is required to have a truly effective compliance program. In a guest article, Brazilian attorney Roberto di Cillo explains how a recent temporary restraining order issued in Brazil may indicate that the company has gone too far in how it is dealing with third-party vendors. See “Lessons on Preventing Top-Down Corruption From the Petrobras Settlement” (Nov. 14, 2018).