Last month, the Justice Department and Securities and Exchange Commission announced a stunning resolution under the FCPA, the Telia Company AB enforcement action. It became Number 1 on the Top Ten list of all-time FCPA settlements with a total amount of $965 million. It also had the highest amount of disgorgement at $457 million. The bribery amount was over $331 million and the corruption went up to the very top of the company. The case had several key areas for consideration by the compliance practitioner.
