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. Allegations From at least 2011- Jan. 2016, Quad/Graphics' Peruvian subsidiary, Quad/Graphics Peru S.A., repeatedly paid, or promised bribes to,…
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DoJ Fine Technip $296mn FCPA
On June 26, DoJ announced settlement of foreign bribery case. TechnipFMC and subsidiary Technip USA agreed to pay over $296mn in FCPA fine. Company is a global provider of oil and gas services, and product of 2017 merger between two predecessor companies, Technip S.A. and FMC Technologies (FMC). Charged 2 separate bribery schemes: Technip Brazil…
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DoJ, SEC Walmart $282mn FCPA
On June 20, DoJ, SEC settled with Walmart for FCPA charges. Walmart agreed to pay SEC about $144mn, and $138mn to DoJ, total of $282mn. Failed to maintain adequate anti-corruption compliance program for about decade. Subsidiaries in Brazil, China, India, Mexico used third-party intermediaries (TPIs) who made payment to foreign government officials without compliance assurance.…
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SEC Fine Repeat FCPA Breach
On Sep. 28, SEC fined Stryker medical $7.8mn FCPA violations. For second time Stryker medical device has been charged with FCPA failures. Alleged Violations Company violated books, records and internal accounting controls provisions. Internal accounting controls did not detect risk of improper payment in sales in India, Chin, and Kuwait, and Indian subsidiary did not…
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SEC Legg Mason $34mn re FCPA
On Aug. 27, SEC settled with Legg Mason for bribery in Libya. Legg Mason charged with breaching the FCPA in a scheme to bribe Libyan officials. Violated internal accounting controls provision of Securities Exchange Act of 1934. Alleged Violations 2004-10 firm’s subsidiary, Permal Group, partnered with a French financial service company to solicit investment business…
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