Compliance Lessons From the Airbus Settlement

In addition to carrying the largest anti-corruption fine in history, the Airbus resolution also has the distinction of being only one of two that covered violation of the U.S. Arms Export Control Act and its implementing regulations, the International Traffic in Arms Regulations (ITAR), in addition to corruption charges. The investigation also uncovered an elaborate system of code words used to mask corruption in email communications. In this second article examining the settlement, we look at how deep Airbus’ compliance failures went and offer lessons for companies seeking to avoid the same pitfalls. A first article examined the significant international cooperation between U.K., U.S. and French enforcement authorities that led to the settlement. A final article will analyze the company’s remediation efforts and how they led to a big penalty but no independent compliance monitor. See “Airbus Case Marks a Milestone in International Anti‑Corruption Cooperation” (Feb. 19, 2020).

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