In this episode, host Michael Volkov takes a closer look at the Honeywell FCPA case. The Justice Department and the FCC had a strong year in FCPA enforcement; they closed out the year with two important cases, ABB and Honeywell. Last week's episode covered the ABB case, and this episode will focus on the Honeywell UOP case, which resulted in a $160,000,000 settlement. 

• Honeywell was involved in a bribery scheme in Brazil and Algeria to secure contracts with state-owned oil companies.
• Honeywell conspired to offer a $4 million bribe to a high-ranking executive of Petrobras in Brazil in an attempt to secure a valuable $425 million contract to design and build a refinery.
• Honeywell's use of third-party agents, such as sales agents, to facilitate bribery payments was done without proper controls and oversight, leading to a lack of proper invoicing, description of services, and confirmation of payment arrangements which facilitated illegal payments.
• Honeywell's senior management was complicit in the scheme and there was a lack of commitment to corporate ethics and compliance culture within the company.
• The case serves as a reminder of the risks to companies of engaging in bribery and the importance of having a strong compliance culture and third-party risk management program.

KEY QUOTE:"Honeywell's actions occurred in an environment where no one raised a question about the bribery scheme. The … narrow focus on winning the project through whatever means possible was clear." - Michael Volkov
RESOURCESHoneywell UOP to Pay Over $160 Million to Resolve Foreign Bribery Investigations in U.S. and BrazilSEC Charges Honeywell with Bribery Schemes in Algeria and BrazilEmail Michael: mvolkov@volkovlaw.com