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FCPA Digest - Trends & Patterns Article (July 2021)

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12 the country. The company entered into a DPA with the DOJ in 2017 and agreed to pay more than $965 million to authorities in the U.S., the Netherlands, and Sweden. Upon the implementation of an enhanced compliance program at the company and in light of its full cooperation with authorities, the DOJ moved to dismiss its charges—a motion the federal judge granted.

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