Swedish telecommunications company Telia, along with its Uzbek subsidiary Coscom, has agreed to settle bribery allegations with the SEC, DOJ, Dutch and Swedish authorities for the eye-watering sum of $965 million in criminal penalties and disgorgement. While the settlement amount is one of the highest in FCPA history, the company was able to obtain a DPA and avoid a monitor through extensive cooperation and remediation efforts. The facts at issue closely mirror those in VimpelCom’s settlement in 2016, but the companies were treated differently by the government. We analyze the case and the outcome. See “VimpelCom Settlement Highlights U.S. Government’s New Holistic Approach to Anti-Corruption Enforcement” (Feb. 24, 2016).