On January 17, 2017, Rolls-Royce plc agreed to pay the United States nearly $170 million as part of an $800 million global resolution with the United States, United Kingdom, and Brazil.  Rolls-Royce entered into a deferred prosecution agreement in connection with charges that the company conspired to violate the anti-bribery provisions of the FCPA.  According to admissions in the agreement, between 2000 and 2013, Rolls-Royce paid more than $35 million in bribes through third parties to foreign officials in Thailand, Brazil, Kazakhstan, Azerbaijan, Angola, and Iraq.  Although Rolls-Royce failed to disclose the conduct to the United States until after the media began reporting allegations of corruption and the UK Serious Fraud Office initiated its investigation, the company received a 25% downward departure from the bottom of the U.S. Sentencing Guidelines fine range on the basis of cooperation with DOJ’s investigation and the significant remedial measures taken by the company. DOJ Press Release