Welcome back to bribes, swindle, or steel.

I'm Alexandra Rogge, and today's guest is a veteran of the Department of Justice,

where he was the assistant chief of the FCPA enforcement unit.

He later served as Senior Vice President, co-general counsel, and chief compliance officer at

Oil and Gas Giant Weatherford International, shepherding them through their FCPA investigation

and settlement in establishing a robust and widely recognized compliance program.

Now, he's a partner at Oric Harrington and Sutcliffe, where he practices in the firm's

FCPA team.

And he's the DOJ appointed compliance monitor for a major petrochemical company.

Billy Jacobson, thank you for joining me.

Thank you. Thank you for having me. Happy New Year.

Happy New Year to you. This is our FCPA year in review for 2017.

So why don't you just start by walking us through the significant

enforcement actions? Sure, happy to. Very interesting year in FCPA enforcement action.

I think many of the most significant actions, at least from a corporate perspective,

stemmed from two large investigations,

multi-jurisdictional and multi-company investigations, those being the Lavajato investigation,

primarily in Brazil, and the Unile investigation. And let me explain what those are broadly,

and then we'll talk about some of the specific cases that fall under those

umbrellas. The Lavajato or Operation Car Wash investigation began in 2014 with a money laundering

investigation concerning a gas station that had a carwash facility prominently attached to it, hence the

name Operation Car Wash or Lavajato in Portuguese.

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