GOL Linhas Aéreas Inteligentes S.A. (GOL), an airline headquartered in São Paulo, Brazil, will pay more than $41 million to resolve parallel bribery investigations by criminal and civil authorities in the U.S. and Brazil, after a partial waiver of payment due to GOL’s financial condition. The conduct surrounded $3.8 million in payments GOL paid between 2012 and 2013 to foreign officials in Brazil to secure the passage of two pieces of legislation related to payroll and fuel taxes, and it serves a good reminder that foreign bribery can happen in the legislative sphere. See “Lessons From Airbus on Third-Party Corruption Risk Mitigation” (May 25, 2022).
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