Profit Sharing as Bribery: The Honeywell FCPA Enforcement Action

Tom Fox reviews recent DOJ and SEC settlements with Honeywell's US subsidiary, over what the DOJ described as “corporate misconduct on a global level.” Honeywell UOP agreed to a criminal penalty of about $80 million (half of that credited for payment to the government of Brazil), and about the same amount paid to the SEC in disgorgement and prejudgment interest (also with about half of that paid to Brazil).