Korea Telecom Corp. (KT), South Korea’s largest telecom company, recently entered into a $6.3‑million settlement with the SEC for violations of the FCPA dating from 2009 to 2018. The case brings several anti-corruption issues to the fore for compliance officers, internal audit leaders, and procurement, finance and HR leaders alike. The methods employees used to finance slush funds draw out the need for not only basic anti-corruption policies and processes, but also more complicated controls that touch on employees’ personal finances and political contributions. See “Evolving Global Anti-Corruption Efforts: U.S., China and India” (Feb. 17, 2021).