Airbus SE, one of the preeminent manufacturers of airplanes, has settled allegations that it used third-party intermediaries to bribe foreign officials to win contracts all over the world and agreed to pay the largest anti-corruption penalty in history. The $3.9 billion in combined penalties will be divided among U.S., U.K. and French enforcement authorities. In this first article in our series examining the case, we take a close look at how the various authorities coordinated their investigation and how Airbus managed these parallel inquiries. A future article will look at the company’s misconduct and how it revamped its compliance program sufficiently to win significant cooperation
credit and avoid an independent compliance monitor. See “How Companies Can Respond to the Boom in FCPA Enforcement Fueled by International Cooperation
” (Oct. 30, 2019).