The Department of Justice and the Securities and Exchange Commission reached a $41 million settlement with GOL Linhas Aéreas Inteligentes S.A. ("GOL") to resolve criminal and civil foreign bribery charges.

GOL entered into a three-year deferred prosecution agreement ("DPA") with DOJ in exchange for payment of a $17 million criminal penalty. DOJ credited $1.7 million of that penalty against a $3.4 million fine that GOL agreed to pay law enforcement authorities in Brazil to resolve charges in Brazil.

In a separate resolution, GOL agreed to pay $24.5 million over two years to the SEC. The SEC's initial settlement calculation was for $70 million, but it was reduced to $24.5 million based on GOL's financial condition.

In this Episode, Michael Volkov reviews the DOJ and SEC FCPA settlement actions.