Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past month, with links to primary resources. This month we ask: Which company resolved bribery investigations with the United States, South African, and Swiss authorities? Which company did the U.S. Department of Justice (DOJ) agree not to prosecute for alleged Foreign Corrupt Practices Act (FCPA) violations? What was the Organisation for Economic Co-operation and Development (OECD)’s assessment of Poland and Finland’s foreign bribery records? The answers to these questions and more are here in our December 2022 Top 10.

1. Swiss Global Technology Company Resolves South Africa Bribery Allegations

On December 2, 2022, DOJ and the U.S. Securities and Exchange Commission (SEC) announced that ABB Ltd. agreed to pay approximately $462 million to resolve bribery investigations by United States, South African, Swiss, and German authorities. The company and two of its subsidiaries admitted to paying, through multiple subcontractors, more than $37 million between 2014 and 2017 to bribe a high-ranking government official at Eskom Holdings Limited, an electricity provider owned by the South African government, to secure a $160 million contract to provide cabling and installation work at Eskom’s Kusile Power Station. DOJ entered into a three-year deferred…