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AT&T will pay $23 million to settle an Illinois bribery investigation.

Following an investigation into bribery paid to influence the Illinois state legislature, an Illinois-based subsidiary of telecommunications giant AT&T will pay $23 million and modify its ethics and compliance procedures.

AT&T Illinois will engage into a deferred prosecution agreement (DPA) to address a federal criminal investigation in which it paid $22,500 to Michael Madigan, former Illinois Speaker of the House, through an intermediary. The business was charged in the United States on Friday.

According to a news statement from the Department of Justice (DOJ), the defendant has been charged with utilising an interstate facility to promote legislative misconduct.

According to the DPA, the DOJ will postpone prosecution on the charge for two years and seek dismissal if AT&T Illinois continues to cooperate with the investigation and implements "a compliance and ethics programme designed to prevent and identify violations of U.S. law throughout their operations."

Compliance considerations: In 2017, AT&T revealed that it arranged for a lobbying firm to pay $22,500 to a Madigan ally in exchange for Madigan's vote and influence over a bill. According to the Chicago Sun-Times, the FBI inquiry also discovered that Commonwealth Edison (ComEd) paid payments to Madigan; the AT&T arrangement resulted in an extra allegation against Madigan and his ally.

In 2020, ComEd paid a $200 million fine and entered into its own DPA with the DOJ.

AT&T dismissed workers who engaged in the scheme and enacted new compliance policies that strengthened internal controls in response to the misbehaviour. According to the DPA, the new policies are as follows:

  • Require internal tracking and reporting of any valuable item requested or solicited by, or provided to, public authorities.

  • Establish requirements for due diligence and continuing supervision of any third parties engaging in political consulting or lobbying operations.

  • Subcontracting of third-party lobbyists and political consultants without previous written authorization is prohibited.

  • All third-party lobbyists and political consultants hired outside of AT&T Illinois must be approved by legal and senior management; and

  • All third-party lobbyists and political consultants must be monitored on an ongoing basis to guarantee they are adding value to the business."

AT&T also stated that it will "adopt a new compliance programme, or modify its existing one, including internal controls, compliance policies, and procedures, to ensure that it maintains a rigorous compliance programme that incorporates relevant internal controls, as well as policies and procedures designed to effectively deter and detect violations of US law."

The company's compliance programme must have "strong, explicit, and visible" support from senior management; it must have proper oversight and be led by one or more senior executives; it must establish a programme for employees to report misconduct internally, including confidentially; it must conduct periodic testing of internal controls to ensure they are implemented effectively; and it must contain internal controls that include record and account maintenance, accordion maintenance, and accordion maintenance.

The corporation must submit a report to the DOJ explaining its remediation efforts within one year, followed by a follow-up report in two years.

AT&T response: “We hold ourselves and our contractors to the highest ethical standards,” an AT&T spokesperson said via email. “We are committed to ensuring that this never happens again.”



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