Total S.A., the France-headquartered multinational oil and gas company, has agreed a deferred prosecution agreement with the US DOJ and has been issued with a cease-and-desist order by the SEC, with the result that Total will pay $398MM in penalties and disgorgement to the US regulators as a result of FCPA violations arising from bribes paid to Iranian officials. As part of the settlement, Total has also agreed to retain an independent corporate compliance monitor for a period of three years, and to continue to implement an enhanced FCPA compliance program. In a coordinated effort, Total, its Chairman, and its CEO are also facing criminal charges in France over the scheme that was the subject of the US investigation.