A critical examination of Ericsson’s 2019 deferred prosecution agreement (DPA) and the Department of Justice’s (DOJ) determination the Swedish telecommunications company breached the agreement raises questions regarding the overall lack of accountability in a yearslong, multijurisdictional corruption scheme.

In December 2019, Ericsson agreed to pay $1 billion in total penalties between the DOJ and Securities and Exchange Commission to resolve a government investigation into violations of the Foreign Corrupt Practices Act (FCPA). Beginning in 2000 and continuing until 2016, Ericsson used third-party agents and consultants to “make and improperly record tens of millions of dollars in improper payments” to government officials in China, Djibouti, Indonesia, Kuwait, Saudi Arabia, and Vietnam, according to U.S. authorities.

The alleged scheme involved sham contracts paid through false invoices managed in off-the-book slush funds. It came at a time Ericsson was reporting growth in its Middle East and North East Asia markets.