Clear Media, a Chinese majority-owned subsidiary of San Antonio-based Clear Channel Outdoor Holdings, Inc. will pay a $6‑million penalty and turn over about $16.4 million in tainted revenue, plus interest, following a September 28, 2023, FCPA resolution with the SEC. The SEC Order alleges that Clear Media bribed Chinese government officials directly and through third parties to win contracts to sell advertisements for display on bus shelters, street furniture and billboards. This article includes insights from Ropes & Gray partner Maria Calvet and Sheppard Mullin partner Jeff Kern. See “Lessons From Airbus on Third-Party Corruption Risk Mitigation” (May 25, 2022).