Telefônica’s Settlement Demonstrates the Dangers of Lavish Hospitality Programs

Telefônica Brasil (Telefônica), the Brazilian subsidiary of Spanish broadband and telecommunications provider Telefónica S.A., recently paid $4.125 million to resolve SEC allegations that it provided Brazilian government officials with tickets to both the 2014 World Cup and the 2013 Confederations Cup in violation of the accounting provisions of the FCPA. The case against Telefônica, the third recent SEC matter involving hospitality programs for government officials at high-profile sports events, serves as a reminder that a quality compliance program must consider a plethora of issues. See “Five Compliance Failures That Led to FCPA Charges for BHP Billiton’s 2008 Olympic Sponsorship Program” (May 27, 2015).

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