Continuing a trend of blockbuster cases involving non-U.S. telecommunications companies, the DOJ and the SEC announced shortly before the end of last year that Stockholm-based company Telefonaktiebolaget LM Ericsson (Ericsson) had agreed to pay upwards of $1 billion to resolve an FCPA matter. Its Egyptian subsidiary pled guilty to one count of conspiracy to violate the bribery provision of the FCPA and the company agreed to retain a compliance monitor for three years, to improve its compliance program and to cooperate with the federal government in any ongoing investigations and prosecutions related to its misconduct. Meanwhile, Ericsson seems to be moving forward despite this billion-dollar blemish on its record. See “Telefônica’s Settlement Demonstrates the Dangers of Lavish Hospitality Programs
” (May 15, 2019).