One of the common goals of both the DOJ’s Corporate Enforcement Policy and the SFO’s Co-Operation Guidance is to encourage companies to self-report corruption issues. But Airbus’ recent $3.9‑billion settlement with U.S., U.K. and French authorities shows that exemplary cooperation, even in the absence of a self-report, can earn a company substantial settlement credit. In this third and final article on the Airbus settlement, we take a close look at Airbus’ cooperation in the parallel investigations, what it did to fix its compliance issues, and how it was able to avoid an independent compliance monitor, despite failing to self-report and paying the largest criminal penalty for an anti-corruption issue in history. See “Airbus Case Marks a Milestone in International Anti‑Corruption Cooperation” (Feb. 19, 2020) and “Compliance Lessons From the Airbus Settlement” (Mar. 4, 2020).