Fulfilling their promise at the recent ACI FCPA conference that there would be another 2022 FCPA corporate resolution, the DOJ and SEC have announced that Swiss-based global technology company ABB Ltd. has agreed to pay more than $315 million and comply with a three-year deferred prosecution agreement to resolve investigations into FCPA violations related to the bribery of a high-ranking official at South Africa’s state-owned energy company. The U.S. authorities cooperated with prosecutorial authorities in South Africa and Switzerland, who each receive a piece of the penalty, with a German action still to come. In addition, Swiss and South African ABB subsidiaries each pleaded guilty to one count of conspiracy to violate the anti-bribery provisions of the FCPA. The resolution is ABB’s third with the DOJ and the SEC dating back to 2001. This case provides a look into U.S. enforcement priorities and declarations regarding voluntary disclosure and cooperation benefits, increased focus on corporate recidivism and multilateral investigations. See our four-part series on the (first) Monaco Memo: “A Roll Back on Individuals and Cooperation” (Jan. 19, 2022); “A Shift in the Monitorship Cost/Benefit Analysis” (Feb. 2, 2022); “Considering All Prior Misconduct” (Feb. 16, 2022); and “The Corporate Crime Advisory Group” (Mar. 2, 2022).