Source: United States Department of Justice Criminal Division
In November 2025, Comunicaciones Celulares S.A., doing business as TIGO Guatemala, a mobile and fixed telecommunications service provider in Guatemala, paid over $118 million to resolve an investigation by the Justice Department into a long-running scheme to bribe government officials in Guatemala. TIGO Guatemala is a wholly owned subsidiary of Millicom International Cellular, S.A. (“Millicom”), an international telecommunications company incorporated and headquartered in Luxembourg that has its principal place of business in the United States.
TIGO Guatemala entered into a two-year deferred prosecution agreement (DPA) in connection with a criminal information filed in the Southern District of Florida charging the company with one count of conspiracy to violate the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA).
According to court documents, between 2012 and 2018, TIGO Guatemala engaged in a widespread and systematic bribery scheme orchestrated by its then-Guatemalan shareholder and other then-senior personnel. The scheme featured monthly bribe payments, usually paid in cash, to numerous Guatemalan members of Congress or members of their security teams, in exchange for, among other things, their support for legislation that benefited TIGO Guatemala. Some of the cash that TIGO Guatemala used to pay bribes were the laundered proceeds of narcotrafficking.
As part of the DPA, TIGO Guatemala agreed to pay a $60 million criminal penalty and $58,198,343 in administrative forfeiture. Pursuant to the DPA, TIGO Guatemala and its corporate parent, Millicom, agreed, among other things, to continue cooperating with the Criminal Division’s Fraud Section and the U.S. Attorney’s Office for the Southern District of Florida in any ongoing or future criminal investigation arising during the term of the DPA. TIGO Guatemala and Millicom also agreed to enhance TIGO Guatemala’s compliance program and to periodically report to the department on remediation and implementation of compliance measures throughout the term of the DPA.
The department reached this resolution with TIGO Guatemala based on a number of factors, including, among others, the nature and seriousness of the offense. In determining the appropriate disposition of this matter, the department gave significant weight to Millicom’s initial voluntary and timely self-disclosure to the Criminal Division in 2015. During the ensuing investigation, however, TIGO Guatemala’s then-Guatemalan shareholder used its operational control to prevent Millicom from accessing critical information, and to prevent Millicom from requiring TIGO Guatemala personnel to cooperate and take remedial actions. The Fraud Section closed its initial investigation in 2018. Two years later, in 2020, the department obtained and proactively developed new evidence from sources other than TIGO Guatemala and Millicom regarding TIGO Guatemala’s conduct and reopened its investigation on that basis. The new evidence revealed the scope of TIGO Guatemala’s conduct, including that the criminal conduct continued during and after the department’s closure of the first phase of the investigation and involved narcotrafficking proceeds that were used to generate cash for some of the bribe payments. Accordingly, TIGO Guatemala did not meet the requirements for a resolution pursuant to Part I or Part II of the Criminal Division’s Corporate Enforcement and Voluntary Self-Disclosure Policy.
However, TIGO Guatemala received credit for its affirmative acceptance of responsibility and substantial cooperation with the second phase of the department’s investigation, which included: (i) Millicom’s self-reporting of conduct that forms, in part, the basis for the DPA; (ii) promptly collecting, analyzing and organizing voluminous information, including complex financial information; (iii) gathering evidence and performing forensic data collections in the countries covered by the department’s investigation; (iv) providing information obtained through its internal investigation, particularly during the second phase of the department’s investigation, which allowed the department to preserve and obtain evidence as part of its own independent investigation; (v) facilitating interviews with employees, including making foreign-based employees available for interviews in the United States; (vi) making detailed factual presentations to the department; and (vii) proactively disclosing evidence about which the department was previously unaware and identifying key documents in materials produced, including Spanish translations.
TIGO Guatemala also engaged in extensive timely remedial measures after the exit of Millicom’s prior joint venture partner and Millicom’s acquisition of full ownership and control of TIGO Guatemala in 2021, including: (i) undertaking a root cause analysis of the misconduct at TIGO Guatemala and risk assessment of the company’s operations; (ii) terminating personnel involved in the bribery scheme; (iii) introducing new and experienced management and compliance personnel to change the local operation’s culture of compliance; (iv) enhancing third-party onboarding and transaction monitoring, including by centralizing and linking the oversight functions under Millicom, incorporating data analytics and automated continuous monitoring across operations and periodically testing relevant controls for effectiveness (including testing of more than 250 transactions); (v) developing an ephemeral messaging policy, which employees are required to acknowledge they have read as part of annual training, and incorporating a system to preserve and analyze TIGO Guatemala employees’ ephemeral messages; (vi) launching an extensive training campaign covering anti-corruption and compliance risks; (vii) quickly incorporating key compliance policies and procedures, and creating a direct reporting line from TIGO Guatemala’s compliance function to Millicom; and (viii) over the last 10 years, significantly restructuring, expanding and resourcing Millicom’s global compliance program, including enhancing its compliance risk assessment process, growing the dedicated compliance headcount by 800% and engaging in continuous monitoring, testing and updating of Millicom’s global compliance program.
In light of these considerations, the criminal penalty reflects a 50% reduction from the bottom of the applicable guidelines range, and the term of the DPA is for a period of two years.
The U.S. Attorney’s Offices for the Southern District of Florida and the Southern District of California previously charged four individuals connected to this scheme.
The FBI is investigating the case.
Trial Attorney Natalie R. Kanerva and Assistant Chief Katherine Raut of the Criminal Division’s Fraud Section and Assistant U.S. Attorney Eli S. Rubin for the Southern District of Florida are prosecuting the case.
The Criminal Division’s Fraud Section is responsible for investigating and prosecuting FCPA and Foreign Extortion Prevention Act matters. Additional information about the Justice Department’s FCPA enforcement efforts can be found at www.justice.gov/criminal/fraud/fcpa.