In what is likely to be the last FCPA enforcement action for some time considering the recent executive order pausing FCPA cases, AAR Corp. (AAR), a publicly traded aviation services company, settled FCPA allegations with the DOJ in December 2024. The terms of the deal illustrate the DOJ’s recently stated willingness to reward companies’ self-reporting efforts even if they already knew about the misconduct. This first article in a two-part series on the case lays out the underlying facts about the bribery schemes in both South Africa and Nepal, and how the company was able to take advantage of recent changes to the DOJ Criminal Division’s Corporate Enforcement and Voluntary Self-Disclosure Policy. The second article will discuss how AAR’s cooperation and remediation efforts enabled it to avoid the imposition of an independent compliance monitor. See “Government Enforcers Explain Their Approach to Whistleblowers and VSD” (Jul. 17, 2024).