Ericsson’s $97‑million direct settlement with competitor Nokia, arising out of its $1‑billion FCPA settlement in December 2019 with the DOJ and the SEC, is an example of one of the unintended consequences of a settlement for companies seeking finality when resolving an FCPA case with the government. In this guest article, Fry Wernick, Palmina Fava, Michael Ward, Christopher James and John Greil, attorneys at Vinson & Elkins, argue that general counsels and compliance officers should include this risk among the “offensive” options to consider upon settling FCPA allegations. They examine the relative rarity of competitor-victim claims that follow from an FCPA resolution, the possibility of an upward trend on the heels of recent support for victim claims and restitution from the DOJ and federal courts, and strategies companies can employ to minimize these collateral risks. See “Lessons from Telecom Giant Ericsson’s Billion-Dollar Record-Setting Deal” (Jan. 8, 2020).