On 24 November, KYC 360 reported that an independent monitor has certified Brazilian construction company Odebrecht SA’s anti-bribery compliance programme.  This closes a 3½-year monitorship that was imposed on Odebrecht as part of a settlement with the DoJ in December 2016.  The monitor has certified that Odebrecht’s compliance programme is designed to prevent future violations of anti-corruption laws, including the FCPA, according to the company.

I had omitted the following link (as it did not seem to generate much interest!), but it seemed time to add it again and say that, if you would like to make a (polite) gesture and help me with my removal and computer costs, I have a page at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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