The Justice Department continues to produce FCPA resolutions in a record year for enforcement. The latest is DOJ’s settlement with Vitol, Inc. (Vitol), an energy trading company. DOJ agreed to a three-year deferred prosecution agreement (DPA) in exchange for a criminal penalty of $135 million. One-third of the payment, or $45 million, would be credited if Vitol pays $45 million to Brazil prosecutors for resolution of the case....
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