Telefónica Venezolana C.A., the Venezuelan subsidiary of Spanish telecom group Telefónica S.A., has settled allegations from the DOJ that it paid officials to get preferential access to hard currency, a precious commodity in Venezuela, necessary to keep business operations going. A range of factors fed into the penalty sum, including the company’s remediation efforts, cooperation with investigators and a previous bribery issue with a different Latin American subsidiary. This article summarizes the bribery scheme, the company’s remediation efforts and what lessons other companies should take away. See “Venezuela Presents High Risk for Foreign Companies” (Sep. 27, 2023).