USA Law and Practice Contributed by: Eric Bruce and Justin Simeone, Freshfields US LLP
7.5 Recent Landmark Investigations or Decisions Landmark Investigations and Decisions Comunicaciones Celulares S.A. In November 2025, Comunicaciones Celulares S.A. (Comcel), a subsidiary of Millicom International S.A., entered into a two-year DPA with the DOJ to resolve alleged violations of the anti-bribery provisions of the FCPA in connection with its business operations in Guatemala. At the time of the conduct, Comcel oper - ated as a joint venture over which Millicom lacked operational control. Comcel paid a USD60 million monetary penalty and forfeited USD58.2 million in proceeds from the conduct. Millicom also agreed to certain obligations, including continued co-operation, compliance reporting, and compliance certifications. The resolution reflects the first criminal FCPA resolu - tion since June 2025, when the Trump Administration lifted a pause on FCPA enforcement and issued new enforcement guidance. Telefónica Venezolana C.A. In November 2024, Telefónica Venezolana, a sub - sidiary of Spain-based Telefónica S.A., entered into a three-year DPA with the DOJ to resolve allegations of conspiracy to violate the anti-bribery provisions of the FCPA. The company paid USD85.2 million in penal - ties after admitting to bribing Venezuelan government officials in 2014 and 2015 to gain preferential access to US dollars through a government-run currency auc - tion. Under the terms of the agreement, Telefónica must enhance its compliance programme, report remediation efforts, and co-operate with ongoing investigations. Notably, despite its later co-operation, Telefónica did not receive credit for voluntary disclo - sure because of its initial failure to produce records and information in the early stages of the DOJ’s inves - tigation. Raytheon Company In October 2024, Raytheon Company entered into agreements with the DOJ, the SEC, and the US Department of State to resolve allegations involving foreign bribery, defective pricing, and export control violations. The DOJ DPA addressed, among other issues, Raytheon’s alleged conspiracy to violate the anti-bribery provisions of the FCPA by engaging in a scheme to bribe a Qatari government official. Under
the DOJ DPA related to FCPA violations, Raytheon paid a USD230.4 million criminal monetary penalty and forfeited USD36.7 million and, under the SEC DPA related to FCPA violations, Raytheon paid a USD75.1 million civil monetary penalty and was subject to disgorgement of USD49.1 million in profits. In total, Raytheon agreed to pay over USD950 million across all settlements related to FCPA- and non-FCPA viola - tions. The resolutions required Raytheon to appoint an independent compliance monitor and implement enhancements to its compliance programme. Domestic Corruption Statutes There have also been high-profile developments involving domestic corruption statutes in recent years, including: • an April 2025 dismissal of federal charges against New York City Mayor Eric Adams for allegedly accepting bribes (eg, luxury travel) in exchange for using his political positions to benefit foreign nationals, businessmen, and others; • an August 2024 federal indictment of Washington, DC Council-member Trayon White for allegedly accepting bribes (eg, cash payments) in exchange for using his political position to benefit multiple government contractors; and • a July 2024 federal conviction of US Senator Robert Menendez for allegedly accepting bribes, including cash and gifts, in exchange for using his political influence to benefit the government of Egypt in violation of US bribery, fraud, extortion, and foreign agent laws. Enforcement Trends The 2024 annual report of the DOJ’s Fraud Section states that the FCPA Unit charged 23 individuals in 2024, 16 of whom were convicted by guilty plea or after trial; in the same year, the FCPA Unit at the Fraud Section reached nine corporate resolutions involving the imposition of USD1.67 billion in global fines, pen - alties and forfeiture. 7.6 Level of Sanctions Imposed FCPA resolutions have included some of the biggest monetary penalties in US criminal and regulatory his - tory. Many penalties have reached into the hundreds of millions of dollars.
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