On December 13, 2024, the United States Attorney’s Offices for the Western District of Virginia and the District of Massachusetts, along with the Department of Justice’s (“DOJ”) Consumer Protection Branch (collectively, “the United States”) filed a Deferred Prosecution Agreement in the United States District Court for the Western District of Virginia with a global consulting firm (“Consulting Firm”) to settle charges that it conspired with a pharmaceutical company (“Pharmaceutical Company”) to aid and abet the misbranding of prescription drugs and knowingly destroyed and concealed records and documents to impede and obstruct the investigation.  United States v. McKinsey & Co., Inc. United States, No. 1:24-cr-00046, Doc. 2 at 6 (W.D. Va. Dec. 13, 2024).  A corresponding civil case, United States v. McKinsey & Co., Inc. United States, No. 1:24-cv-00063, Doc. 2 (W.D. Va. Dec. 13, 2024), was settled the same day.  The Consulting Firm agreed to pay $650 million to resolve the criminal and civil investigation.  A former Consulting Firm senior partner also separately pled guilty to a charge of knowingly destroying and concealing records and documents to impede and obstruct the investigation.

On August 10, 2023, the U.S. Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), in coordination with Columbian authorities, announced that Colombian conglomerate Grupo Aval Acciones y Valores S.A (“Grupo Aval”) and its banking subsidiary Corporacion Financiera Colombiana S.A. (“Corficolombiana”) agreed to pay approximately $80 million USD for their alleged involvement in a scheme to pay $23 million USD in bribes to high-ranking government officials in Colombia, in violation of the anti-bribery provisions of the Foreign Corrupt Practices Act (“FCPA”).  In resolving these allegations, Corficolombiana entered into a three-year Deferred Prosecution Agreement (“DPA”) with the DOJ, and agreed to pay a $40.6 million USD criminal penalty, up to half of which may be credited against payments to the Columbian government.

On March 2, 2023, the Department of Justice (“DOJ”) announced that a multinational telecommunications company headquartered in Stockholm, Sweden (the “Company”) agreed to plead guilty and to pay a penalty of approximately $206 million after allegedly breaching the cooperation and disclosure provisions of a 2019 Deferred Prosecution Agreement (“DPA”) it had previously entered into to address claims that it participated in a scheme to pay bribes, falsify books and records, and failed to implement reasonable internal accounting controls in violation of the Foreign Corrupt Practices Act (“FCPA”).

On December 14, a multinational telecommunications company headquartered in Stockholm, Sweden (the “Company”), announced it had reached agreement with the U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) to extend the Company’s independent compliance monitorship by one year, to June 2024.  The agreement to extend the monitor, which had been required under a 2019 resolution with the DOJ, was the result of the DOJ determining that the Company had failed to adequately disclose compliance matters that it had investigated in Iraq.