Blog Posts Tagged With FCPA

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In re Juniper Networks, Inc. (A.P. Aug. 29, 2019, Settled)

Action against Respondent, a networking equipment product and service company, for alleged violations of the books and records and internal controls provisions of the FCPA.  According to the SEC, sales employees of Respondent’s foreign subsidiaries agreed with third-party channel partners to increase the incremental discount provided to customers through those partners without passing the discounts on to customers.  The SEC alleges that the channel partners diverted the discounts for personal and marketing expenses, including trips
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In re Deutsche Bank AG (A.P. Aug. 22, 2019, Settled)

Action against Respondent, a financial services corporation, for alleged violations of the books and records and internal accounting controls provisions of the FCPA.  According to the SEC, Respondent provided employment to the relatives of foreign government officials to influence them to assist the bank in obtaining or retaining business or other benefits.  The SEC further alleges that Respondent did not enforce a hiring policy enacted to prevent such conduct, that its books and records did
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In re Microsoft Corporation (A.P. July 22, 2019, Settled)

Action against Respondent, a technology company, for alleged violations of the books and records and internal controls provisions of the FCPA.  According to the SEC, Respondent’s subsidiary in Hungary provided resellers and other third parties with discounts that were used to fund improper payments to government officials.  The SEC further alleges that Respondent’s subsidiaries in Saudi Arabia and Thailand used resellers and other third parties to provide improper travel and gifts to government officials.  Finally,
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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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