Ericcsson's stock is traded in the U.S. on NASDAQ, so it is subject to the FCPA
FCPA training and compliance is a big deal. I have sat through FCPA training at several of the Silicon Valley companies I worked for. I can specifically remember FCPA training at Unity Technologies, Symantec, Cisco, Saavis Inc and one now very defunct startup I was at. I am sure there are other companies I have been at whose training on this subject I have forgotten.
Ericsson is listed in the U.S., and their personnel in their U.S. operations may have been involved in the bribery in question or covering up that bribery. Technically, you can have someone from Ericsson's offices outside the U.S. go to the U.S. on a business trip and conduct activity in support of this bribery while in the U.S., and that makes them and Ericsson liable under the FCPA. That is true even if that non-U.S. employee never sets foot in the U.S. again. That is to keep American multinationals from offshoring their corrupt practices to overseas offices, subsidiaries and personnel, while proclaiming that their American operations and personnel are completely innocent of activities banned by the FCPA.
From the Wikipedia page on the Foreign Corrupt Practices Act.
"The core aim of the Foreign Corrupt Practices Act (FCPA) is to prohibit companies and their individual officers from influencing foreign officials with any personal payments or rewards. The FCPA applies to any person who has a certain degree of connection to the United States and engages in corrupt practices abroad, as well as to U.S. businesses, foreign corporations trading securities in the U.S., American nationals, citizens, and residents acting in furtherance of a foreign corrupt practice, whether or not they are physically present in the U.S. This is considered the nationality principle of the Act. Any individuals involved in these activities may face prison time.[page needed]
In the case of foreign natural and legal persons, the Act covers their deeds if they are in the U.S. at the time of the corrupt conduct. This is considered the protective principle of the Act. Moreover, the FCPA governs not only direct payments to foreign officials, candidates, and parties, but payments made to any other recipient in furtherance of influencing a foreign official, candidate, or party. These payments are not restricted to monetary forms and may include anything of value. This is considered the territoriality principle of the act."