Brazilian airline Gol agreed to pay $41 million as part of reduced settlements addressing bribery investigations conducted by authorities in the United States and Brazil.

Gol, a partner airline of American Airlines and Air France, paid bribes to Brazilian government officials in an effort to pass legislation in Brazil that it favored, the U.S. Department of Justice (DOJ) announced Thursday. Gol reached separate resolutions with the Securities and Exchange Commission (SEC) as well as the Comptroller General and Attorney General’s Office in Brazil.

The airline violated the anti-bribery, books and records, and internal accounting controls provisions of the Foreign Corrupt Practices Act (FCPA), the U.S. agencies said.

Gol admitted it conspired to pay about $3.8 million in bribes to Brazilian legislators from 2012-13 to influence the passing of two pieces of legislation that would lower the company’s fuel and payroll taxes, the DOJ said. The airline created an elaborate scheme to paper over the bribes by having a member of its board of directors enter sham contracts with entities connected to the people accepting the bribes.

A Gol director authorized one of the payments be sent from a company he owned in the Bahamas to a U.S.-based company owned by a close associate of one of the Brazilian officials, according to the SEC’s order. The $350,000 payment was wired from a bank account in the Bahamas to a bank account in Switzerland that belonged to the U.S. company. The bribe was transmitted through a U.S.-based correspondent bank, the SEC determined.

Gol listed the corrupt payments on its books as “advertising expenses” and other legitimate payments, the DOJ said.

Gol entered into a three-year deferred prosecution agreement (DPA) with the DOJ, filed in U.S. District Court for the District of Maryland, related to criminal charges of conspiracy to violate the FCPA. The airline will pay a criminal penalty of $17 million, with up to $1.7 million credited against a $3.4 million fine the company must pay to the Brazilian authorities.

The DOJ originally told Gol it must pay a criminal penalty of $87 million, but the company made a credible claim it would not be able to pay that amount, resulting in the reduction.

Gol will pay $24.5 million to the SEC, the agency announced. The SEC had originally levied a $70 million penalty against the company before reduction.

Both U.S. agencies took Gol’s cooperation with their investigations into consideration when agreeing to lower the penalties.

Compliance considerations: Both the SEC and DOJ described Gol’s compliance program as inadequate and said it must be remediated to prevent future corruption at the company.

“This case highlights the need for internal accounting controls that are effective for transactions initiated at all levels of an organization,” Charles Cain, the SEC’s FCPA Unit chief said. “Gol’s internal accounting controls were particularly ineffective for transactions initiated by those at its highest levels.”

The company agreed to implement a compliance and ethics program designed to prevent and detect violations of the FCPA, including among contractors and foreign officials who are at high risk of corruption, according to the DPA.

The company also agreed to review its internal accounting procedures to ensure it is keeping fair and accurate records and accounts and controls and policies to prevent violations of the FCPA. The company agreed to provide annual reports concerning its compliance program and accounting controls to the DOJ.

Gol cooperated with the investigation by sharing with investigators information from its internal investigation in a timely manner and by making factual presentations to investigators, translating documents, sharing all facts related to the individuals involved in the bribery, and other actions, according to the DPA.

The airline agreed to cooperate with any future investigations related to the bribery, according to the DPA.

In remarks delivered at the University of Texas Law School on Friday, Assistant Attorney General Kenneth Polite Jr. of the DOJ’s Criminal Division acknowledged the agency will seek assurance from Gol’s chief compliance officer regarding the standing of the company’s program at the end of the DPA, in line with the DOJ’s new certification requirements.

“We did not impose a monitor in [the Gol case] because at the time of the resolution, the company had redesigned its entire anti-corruption compliance program, demonstrated through testing that the program was functioning effectively, and committed to continuing to enhance its compliance program and internal controls,” Polite said. “However, to ensure follow-through on this commitment, and because the Gol case involved bribery of foreign officials, we will require the CEO and CCO to certify at the end of the DPA term that the ‘compliance program is reasonably designed to detect and prevent violations of the [FCPA] and other applicable anti-corruption laws throughout the company’s operations.’”

Gol response: The airline said in a statement none of its current employees or management were “aware of any illegal purpose behind any of the identified transactions or of any illicit benefit to Gol arising out of the investigated transactions.”