While the resolution of the Telia Company (Telia) Foreign Corrupt Practices Act (FCPA) matter has long been awaited, the results announced in September by the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) were stunning nonetheless.
It is one of the largest FCPA resolutions of all-time, with a total fine and penalty of $965MM, which include $457MM in profit disgorgement, also a new number one figure.
In this white paper, Tom Fox explores the resolution and what lessons the compliance practitioner can draw from the case, the parallel actions and what it may portend for FCPA enforcement going forward under the Sessions DOJ.