If a company refuses to disclose certain documents, prosecutors will determine whether the refusal is justified under the rules in force. In the event of a disagreement between the attorney and the company over the privilege, the attorney may consider the refusal to disclose the disputed information as a lack of cooperation. The agreement is not the first agreement reached by Camargo and the Brazilian authorities as part of Operation Car Wash. In January 2017, Camargo asked 40 of its executives Plea Agreements, and in August 2015 to pay 700 million reais (about $173 million) to Brazilian state-owned enterprises as damages related to corruption and price settlement.  In 2019, the drum was set in favor of non-repressive agreements (“NPA”) and deferred prosecution agreements (“DPA”)  and we continue to find that these agreements are often used by prosecutors to resolve complex corporate enforcement actions. Despite constant scrutiny, PDOs and PDOs have withstood the political vicissitudes and comings and goings of administrations and agency heads; They passed the test of the time and we saw them become more and more demanding year after year, as regulators and practitioners both learn from past agreements and refine the key language to achieve the desired results. . . .