In July, the Justice Department and Securities and Exchange Commission concluded the long-running Foreign Corrupt Practices Act (FCPA) enforcement action involving the LATAM Airlines Group S.A. (LATAM). The settlement documents released included details on the criminal charges; a Deferred Prosecution Agreement (DPA); and a Securities and Exchange Commission (SEC) Cease and Desist Order (Order) outlining the civil violations. LATAM’s predecessor-in-interest is LAN Airlines S.A. (LAN).

Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in...