Last week, the U.S. Department of Justice (DOJ) announced an $85.2 million settlement with Telefónica Venezolana, the Venezuelan subsidiary of the Spanish telecommunications giant Telefónica, S.A. The case, resolved through a deferred prosecution agreement, was for conspiracy to violate the Foreign Corrupt Practices Act (FCPA). At first glance, it appeared to be a standard FCPA enforcement action: a multinational subsidiary bribing foreign officials to secure a business advan
