SEC $10mn for Printer FCPA Breach

On Sep. 26, SEC settled with print-marketer for $10mn re FCPA.

  • Charged Quad/Graphics, digital and print marketing provider, based in Wisconsin-USA.
  • For company violations of the FCPA by engaging in bribery schemes in Peru and China.


  • From at least 2011- Jan. 2016, Quad/Graphics' Peruvian subsidiary, Quad/Graphics Peru S.A., repeatedly paid, or promised bribes to, government officials within Peru.
  • These bribes were in order to win sales contracts and avoid penalties, and improperly attempt to influence the judicial outcome of a dispute with the Peruvian tax authority.
  • Defendants created false records to hide transactions with a State-controlled Cuban telecommunications company, which was sanctioned by US and export controls laws.
  • Between 2010-15, China-based subsidiary used sham sales agents to make improper payments to private and governmental employees of customers to secure business.


  • Quad/Graphics has been issued with a cease-and-desist order, and has agreed to pay $6.9mn in disgorgement, $959k in prejudgment interest, and a $2mn civil penalty.
  • Company also agreed to self-report on its compliance program for a one-year period.