Trends in multi-jurisdictional enforcement of anti-corruption in the global petroleum industry.

This article focuses on the increasing trend of multi-jurisdictional enforcement of foreign bribery laws in the global petroleum industry over the past decade. It highlights how coordinated prosecutions by multiple national authorities, particularly led by the U.S. Department of Justice under the Foreign Corrupt Practices Act (FCPA), have raised the financial and reputational risks for petroleum companies operating internationally. The study profiles major corruption cases, such as the Unaoil and Odebrecht/Petrobras scandals, illustrating common patterns involving third-party intermediaries, shell companies, and executive-level complicity. It also discusses the limited application of international double jeopardy (ne bis in idem) principles, which allows multiple jurisdictions to prosecute the same conduct independently. The article concludes that despite regulatory calls for risk-based anti-corruption compliance, the petroleum industry largely lacks robust risk management practices and recommends adopting established global risk standards like ISO 31000 to better manage multi-jurisdictional corruption risks.