On November 12, Dutch oilfield company SBM Offshore N.V. announced that it had agreed to pay $240 million to the Dutch Public Prosecutor’s Office to resolve an investigation into allegedly corrupt payments made to win contracts in several countries around the world. SBM also stated that the U.S. Department of Justice had simultaneously closed its investigation into the same matter, but news reports indicated that Brazilian and U.S. authorities were investigating payments made by SBM to Petrobras, the Brazilian state-owned oil company. The investigation in Brazil is part of a widening investigation into various allegations of corruption involving Petrobras, which has portrayed itself as a victim rather than perpetrator of misconduct.

As to SBM Offshore, the Department of Justice’s apparent willingness to accept the company’s resolution with Dutch authorities is an encouraging indication that U.S. authorities are increasingly cognizant of the need to avoid imposing “double jeopardy” on multinationals. Moreover, while the Netherlands were termed as having “little or no enforcement” in Transparency International’s recent “Exporting Corruption — Progress Report 2014: Assessing Enforcement of the OECD Convention on Combating Foreign Bribery,“ this action seems certain to change perceptions about Dutch anti-corruption enforcement activity.