Dorsey Anti-Corruption Digest - October 2017

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Sweden-based Telia Company AB has agreed to pay $965 million to settle Foreign Corrupt Practices Act (FCPA) charges with the Department of Justice (DOJ) and Securities and Exchange Commission (SEC). U.S. v. Telia Co., No. 17-cr-60581 (S.D.N.Y. Filed Sept. 20, 2017); In the Matter of Telia Company AB, Adm. Proc. File No. 3-18195 (Sept. 21, 2017). To settle with the DOJ Telia subsidiary, Coscom LLC, pleaded guilty to one count of conspiracy to violate the anti bribery provisions of the FCPA and parent-company Telia entered into a deferred prosecution agreement (DPA). In settling with the DOJ, the firm will pay a criminal penalty of $274,603,972. That includes a $500,000 criminal fine and $40 million in criminal forfeiture paid on behalf of Coscom. To settle with the SEC Telia, a U.S. issuer until 2007 when the firm terminated its registration, the firm consented to the entry of a cease and desist order based on Exchange Act Sections 30A and 13(b)(2)(A). Telia will also pay disgorgement and prejudgment interest of $457,159,977. The $40 million paid to the DOJ as forfeiture will be credited against that amount.

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