Honeywell Project
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Giovanna Malagon
CoPIs:
Dante Lateano, Will Marin, Rachelle Lopez, Andrei Hulpoi, Stephany Lopez
College:
College of Business and Public Management
Major:
Marketing
Faculty Research Advisor(s):
Dawn Adams-Harmon
Abstract:
The case concerns claims that, between 2010 and 2014, Honeywell UOP paid bribes to a senior executive at Petrobras, the state-owned oil firm of Brazil. The Southern District of Texas received a criminal information from the U.S. Department of Justice (DOJ) accusing Honeywell UOP of conspiring to violate the Foreign Corrupt Practices Act (FCPA). In accepting the accusations and agreeing to specific terms, Honeywell UOP and the DOJ entered into a three-year deferred prosecution agreement. A criminal penalty of about $79 million is included in the DPA, with a portion credited against payments to be paid in Brazil. In addition, there will be an additional disgorgement and prejudgment interest of around $81 million related to a concurrent SEC investigation. According to reports, Honeywell UOP paid the Petrobras official a $4 million bribe in order to gain and hold onto business, namely in relation to a $425 million contract for the Premium oil refinery project. Honeywell UOP made about $105.5 million from the deal that was secured through corruption. With a separate payment to the SEC and a partial credit against sums owed in Brazil, the business will pay a total of more than $160 million. Coordination between the DOJ, Brazilian prosecution authorities, and the SEC is required to resolve the matter. The investigations are being conducted by the IRS Criminal Investigation (CI) Houston Field Office and the FBI Washington Field Office. Credit was given to Honeywell UOP for their cooperative efforts in the investigation, which included proactive disclosure, internal investigations, interview facilitation, and the provision of pertinent documents. The business strengthened its compliance program and fired and disciplined the workers who had engaged in the misbehavior as part of its corrective actions. The case shows how Brazilian and American authorities work together to fight global corruption. In relation to the conduct, Honeywell UOP has committed to keep assisting with any current or upcoming criminal investigations. During the DPA's length, the business and its parent, Honeywell International Inc., promised to improve its compliance procedures and give reports to the DOJ. Assistant U.S. Attorney Suzanne Elmilady for the Southern District of Texas, Assistant Chief Gerald M. Moody Jr., and Trial Attorney Gwendolyn Stamper of the DOJ's Criminal Division's Fraud Section are prosecuting the case.