On September 21, 2017, the Department of Justice announced that Swedish-based Telia Company entered into the third largest ever global FCPA resolution with $965 million in combined disgorgement and criminal penalties.  The settlement concluded investigations conducted by the U.S. Department of Justice, the U.S. Securities and Exchange Commission, and Swedish and Dutch authorities.  Telia is a multinational telecommunications company and the dominant telephone and mobile network company in Sweden, Finland, and the Baltic region.  Telia was charged in a one-count Information with conspiracy to violate the anti-bribery provisions of the FCPA, and in its deferred prosecution agreement, agreed that it participated in a conspiracy with its Uzbek subsidiary, Coscom LLC.  For its part, Coscom was charged with, and pled guilty to, one count of conspiring to violate the anti-bribery provisions of the FCPA.

According to the DOJ, between approximately 2007 and 2012, Telia and Coscom paid more than $331 million in bribes to illegally obtain telecommunications business in Uzbekistan.  DOJ alleged:  “The bribes were paid to an Uzbek government official who was a close relative of a high-ranking government official and who exercised influence over Uzbek telecommunications industry regulators.  Telia and Coscom structured and concealed the bribes through various payments to a shell company that certain Telia and Coscom management knew was beneficially owned by the foreign official.  The bribes were paid on multiple occasions over a period of approximately five years so that Telia could enter the Uzbek market and Coscom could gain valuable telecom assets and continue operating in Uzbekistan.” The DOJ described a scheme where “under the direction and control of the Uzbek government official, more than $331 million in bribery proceeds were laundered through accounts held in various countries around the world.”

In total, Telia agreed to pay criminal penalties totaling approximately $548.6 million and to disgorge approximately $457 million in profits and prejudgment interest, making it one of the most expensive FCPA settlements in history.  In addition, three former Telia executives, including the former CEO, have been charged by the Swedish Prosecution Authority with bribery offenses.