This week, we are pleased to have a guest post from Kevin Daly.  Attorney Daly is a member of the firm’s Manufacturing Industry Group and also its Trade Compliance Team.

In September, the U.S. government announced a nearly $1 billion FCPA (Foreign Corrupt Practices Act) settlement with the Swedish telecommunications company Telia.  The total monetary payment in this global resolution makes it the largest such settlement to date.  It is also the first major FCPA settlement under the Trump Administration.

The settlement involved both Telia itself and its Uzbek subsidiary, Coscom.  The settlement resolved allegations that the two companies paid over $330 million in bribes to an Uzbek government official in an attempt to enter the telecommunications market in Uzbekistan.  The official had influence over the Uzbek agency that regulates the telecommunications industry.  Telia and Coscom also allegedly concealed the bribes by routing them through shell companies.

The settlement was a global resolution involving the Department of Justice, the Securities and Exchange Commission, as well as Swedish and Dutch authorities.  It imposed total civil and criminal monetary penalties of over $965 million.  Telia entered into a deferred prosecution agreement, agreed to implement internal controls, and agreed to cooperate with the government’s ongoing investigation.  Coscom pleaded guilty to one count of conspiracy to violate the FCPA.

Ever since the Trump Administration began in January, observers of government anti-corruption policy have sought to predict whether FCPA enforcement would change under the new administration.  One cannot draw too many conclusions from a single settlement, and it is unclear whether any other settlements of this magnitude are on the horizon.  But, for the time being at least, the era of major global anti-corruption resolutions continues.

The Department of Justice’s press release announcing the Telia settlement can be found here.