On September 15, 2022, the Department of Justice (DOJ) and the United States Securities and Exchange Commission (SEC) announced that GOL Linhas Aéreas Inteligentes S.A. (GOL), an airline headquartered in São Paulo, Brazil, agreed to pay more than US$150m to resolve parallel investigations by criminal and civil authorities in the US and Brazil, stemming from conduct relating to improper payments to secure favorable legislation. As an issuer on a US stock exchange, GOL is subject to the Foreign Corrupt Practices Act (FCPA). This is the second international FCPA action in as many years against an airline, the first being the record-breaking US$3.9bn settlement with Airbus SE. Read our full update here.
