In a December 2018 enforcement settlement, the SEC and Brazil’s Centrais Elétricas Brasileiras S.A. (“Eletrobras”) agreed to violating books and records and internal accounting controls requirements and paid a $2.5 million penalty.  (Here). DOJ declined to prosecute Eletrobras. Eletrobas stock is traded on the New York Stock Exchange.  The Brazilian government owns 51 percent of Eletrobras and appoints seven of eleven board members. The bribery...