Telefônica Brasil, S.A., the largest telecommunications company in Brazil with shares traded on the New York and B3 (Brazil) stock exchanges, settled FCPA books and records and internal controls charges with the SEC. Telefônica agreed to pay a civil penalty of $4,125,000. The SEC’s charges were based on entertainment that Telefônica provided to government officials who were directly involved with, or in a position to influence, legislative actions and regulatory approvals related to the company. Specifically, the SEC alleged that Telefônica provided tickets and related entertainment for the 2014 World Cup to 93 government officials and tickets and hospitality for another international soccer tournament in 2013 without reflecting the transactions accurately in the company's books and records. The payments were recorded as “publicity institutional events” or “advertising & publicity.” The SEC also alleged that the company failed to enforce its corporate anti-bribery and anti-corruption policies and failed to devise and maintain a sufficient system of internal accounting controls. The SEC noted that in reaching the settlement, it took into account Telefônica's cooperation, which included the voluntary production and translation of documents and sharing facts developed in the company's internal investigation, as well as the company’s adoption of new anti-corruption policies and compliance structures.