Flutter Entertainment, owner of PokerStars and other online gaming brands, agreed to pay a $4-million civil penalty to the SEC earlier this year, in connection with a predecessor company’s payments to consultants in Russia. The company, which is based in Ireland and listed on the London Stock Exchange, had withdrawn from the Russian market following Russia’s invasion of Ukraine in 2022. Payments were made to consultants in Russia in an effort to have online poker legalized in that country. The case is remarkable for the length and breadth of the SEC’s investigation along with the imposition of a multi-million-dollar penalty despite cooperation, remediation and some apparent self-disclosure. This article distills remarks by Coates Lear, a member of Shoemaker Ghiselli & Schwartz; Jane Shvets, a partner at Debevoise & Plimpton; Guillermo Christensen, a partner at K&L Gates; Clare Pozos, a partner at Dechert; Michael Casey, a partner at Wilson Sonsini Goodrich & Rosati; Leah Moushey, counsel at Miller; and Paul Calli, a partner at Calli Law. See "How M&A Impacted FCPA Enforcement and Guidance” (Jan. 20, 2021); and “The Compliance Value-Add” (Mar. 3, 2021).