February 2020

DOJ Issues Declination for Public Agricultural and Energy Multinational

A Fortune 100 agricultural and energy multinational engaged Faegre Drinker to investigate potential misconduct involving Mexican customs agents, various questionable business practices in China and, subsequently, complex and potentially problematic business relationships and transactions in several other jurisdictions. We made a voluntary self-disclosure to the DOJ and SEC. This was a complex, multi-jurisdictional and multi-year investigation that resulted in the client unwinding a strategic relationship, terminating certain third party intermediaries and instituting numerous other remedial actions. While a final decision by the SEC is pending, the DOJ issued a declination of enforcement relative to all matters under review, including for reason of the company’s robust investigation and full cooperation with the government.

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