Albemarle’s bribery schemes look and sound like text-book examples of third-party agents being paid high commissions as a way to funnel bribery payments to foreign officials at state-owned oil refineries.  However, as usual, there is more than meets the eye in the factual descriptions. The DOJ and SEC settlements focused on bribery conduct in Vietnam, Indonesia and India.  However, the SEC also cited Albemarle’s control...