On September 21, 2017, Telia Company AB entered into a global settlement under which is agreed to pay a combined total penalty of $965 million for a scheme to bribe a government official in Uzbekistan. According to court documents, Telia and its Uzbek subsidiary, Coscom, paid approximately $331 million in bribes to an Uzbek government official, who was closely related to another high-ranking official, in exchange for access to the Uzbek telecom market. Payments were made and concealed using several payments to a shell company that Telia and Coscom managers knew was beneficially owned by the Uzbek official. Telia entered into a deferred prosecution agreement with the DOJ for conspiracy to violate the anti-bribery provisions of the Foreign Corrupt Practices Act (“FCPA”), while Coscom pled guilty to the same count, agreeing to pay a penalty of approximately $275 million, including a criminal fine of $500,000 and $40 million in forfeiture of assets. Separately, Telia agreed to pay approximately $457 million in disgorgement of profits plus interest pursuant to a resolution with the SEC, to which it will credit any profits that Telia ultimately disgorges to foreign regulators in the Netherlands and Sweden, as well as the $40 million in forfeiture to the DOJ. In a separate resolution with Dutch authorities, Telia agreed to pay the Public Prosecution Service of the Netherlands (Openbaar Ministrie or “OM”) a criminal penalty of $274 million which the DOJ agreed to credit as part of its deferred prosecution agreement with the company. The combined amount of all criminal and regulatory penalties paid by Telia and Coscom totals $965,773,949. U.S. v. Telia Company AB, 17-cr-00581 (S.D.N.Y.).