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Lessons from the Telia FCPA resolution

Tom Fox | October 11, 2017

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.

FCPA enforcement. While certainly the lion’s share of the work on this case was done under the prior administration, the matter provided clear guidance that under Attorney General Jeff Sessions, the Justice Department will actively and aggressively prosecute clear legal wrongdoers. For companies with systemic, wide-ranging corruption baked into their business plans, the price will be steep. Further, if there is involvement with the very top management,...

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