Airlines Services Limited’s DPA with the SFO has been judicially approved, and the now-defunct company will pay approximately £2.98 million ($3.99 million) to resolve the commercial bribery case, which highlights the risk of commission structures and the failure to follow through on anti-bribery programs. We analyze the case, the ninth DPA for the SFO since the resolution tool was introduced. See “What Does a ‘Bigger and Stronger’ SFO Mean for Companies?” (Nov. 28, 2018).