DOJ FCPA Settlement: J&F Investimentos’ Bribery Schemes (Part II of V)
J&F’s Investimentos bribery scheme was pervasive and was coordinated with a senior Brazilian Finance minister and orchestrated through the use of United States banking. The Brazilian official appears to be Guido Mantega, who went on to serve as Brazil’s finance minister. Given J&F’s large penalty in Brazil, DOJ’s resolution was reasonable in light of the consistent use of the US banking system to execute the...