Blog Posts Tagged With FCPA

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In re Walmart Inc. (A.P. June 20, 2019, Settled)

Action against Respondent, a retailer, for alleged violations of the FCPA’s books and records and internal accounting controls provisions.  According to the SEC, Respondent’s subsidiaries in Brazil, China, India, and Mexico lacked sufficient internal anticorruption controls and, as a result, employed third-party intermediaries who made improper payments to foreign government officials.  The SEC further alleges that Respondent failed to adequately investigate allegations of corruption and mitigate known risks.  Respondent has agreed to pay disgorgement of
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In re Fresenius Medical Care AG & Co. KGaA (A.P. Mar. 29, 2019, Settled)

Action against Respondent, a German medical products and services company, for alleged violations of the FCPA’s anti-bribery, books and records, and internal accounting provisions. According to the SEC, Respondent made improper payments in a number of different countries to obtain business and failed to maintain adequate accounting controls and compliance measures. Respondent has agreed to pay disgorgement of $135 million and prejudgment interest of $12 million. The SEC did not impose a penalty due to
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SEC v. Gordon J. Coburn and Steven E. Schwartz (D.N.J. Feb. 15, 2019, Contested); In re Cognizant Technology Solutions Corporation (A.P. Feb. 15, 2019, Settled)

Actions against Respondent, a technology company, and Defendants, two of Respondent’s former executives, for alleged violations of the FCPA’s anti-bribery, books and records, and internal accounting controls provisions.  According to the SEC, Respondent and Defendants paid bribes through a contractor to Indian officials to obtain operating licenses and construction permits.  The SEC alleges that Respondent and Defendants falsified documents in order to conceal the payments.  Respondent has agreed to pay disgorgement of $16,394,351, prejudgment interest
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In re Polycom, Inc. (A.P. Dec. 26, 2018, Settled)

Action against Respondent, a communication product company, for alleged violations of the FCPA’s books and records and internal accounting controls provisions.  According to the SEC, Respondent’s subsidiary provided discounts to distributors and resellers with the understanding that the discounts would be used to make cash payments to government officials who had influence over purchasing decisions.  The SEC further alleges that Respondent failed to maintain adequate accounting controls and lacked an effective anti-corruption compliance program with
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In re Centrais Elétricas Brasileiras S.A. (A.P. Dec. 26, 2018, Settled)

Action against Respondent, a partially state-owned Brazilian energy company, for alleged violations of the FCPA’s books and records and internal accounting controls provisions.  According to the SEC, officers of Respondent’s subsidiary engaged in a scheme to rig construction bids, inflate contract prices, and pay bribes to government officials.  The SEC further alleges that Respondent’s accounting controls were inadequate.  Respondent has agreed to pay a civil penalty of $2.5 million.

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SEC Administrative Summary
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