Welcome back to the podcast, bribes,windle, or steal. I'm Alexandra Ragi. Today I'm speaking

with Ashling O'Shea. Ashling is co-head of Sullivan and Cromwell's FCPA and Anti-Corruption Group and a member of the

firm's litigation group. Her practice focuses primarily on criminal defense,

government investigations, and the FCPA. Prior to joining Sullivan and Cromwell,

Ashling spent five years at the Department of Justice as a trial attorney in the criminal

division's fraud section. For our purposes today, we're going to tap into Ashling's

FCPA expertise to walk through the recent Airbus settlement.

Ashling, thank you for joining me.

Thanks so much for having me.

Airbus, a deferred prosecution agreement, almost $4 billion.

Why don't you take us through this?

This was a fairly blockbuster settlement that came out at the end of the last month. It is the largest ever

global foreign bribery resolution as parties to the resolution were the United States,

France, and the United Kingdom. And what we've seen here in the Airbus resolution is really

an unprecedented level of international cooperation, which I think

is going to end up being the long-term takeaway of the resolution. Why don't we go right back to the

beginning? When was the misconduct? And how did it come to light? The misconduct, and I'm going to focus now

on the misconduct as reflected in the DPA with the United States because there are

slightly different time periods in the agreements. And I think the U.S. and the French ones

cover the longest time period. The U.S. DPA covers the period of 2008 to 2015 and involves,

as the statement of facts characterized it, a massive scheme to pay bribes

to decision makers and other influencers, including foreign officials in multiple countries

...