John Davis, Coordinator of Miller & Chevalier's FCPA & International Anti-Corruption practice, commented on Foreign Corrupt Practices Act (FCPA) violation conspiracy charges against five former Rolls-Royce executives. In January 2017, the Department of Justice (DOJ) announced that U.K.-based Rolls-Royce had agreed to pay the U.S. $170 million as part of an $800 million global settlement, which resolved U.S., U.K. and Brazilian investigations into efforts to bribe government officials in exchange for government contracts. The conduct of the five individuals the DOJ has pursued appears to be "the same conduct summarized in the U.S. Deferred Prosecution Agreement (DPA), which was focused on the activities of the Rolls-Royce energy subsidiary based in Ohio," Davis said. The settlements Rolls-Royce entered into with the U.S. and the U.K., however, "appear largely to cover separate sets of conduct by different subsidiaries in different countries, although there may be some overlap in coverage," he added. Rolls-Royce's commitment to cooperate is ongoing. Corporate cooperation is "considered by DOJ to be a requirement for any company pursuing an FCPA-related settlement," Davis said. "The DPA also contains a requirement that the company continue to cooperate with any and all investigations related to the same conduct by U.S. and foreign authorities, including investigations of present and former employees, agents and consultants."