Public Company Avoids FCPA Enforcement

A public automotive industry company engaged Faegre Drinker to lead a FCPA investigation into misconduct in South Korea and China involving employee conflicts of interest; improper use of third-party intermediaries; misuse of vendors and gifts, travel and entertainment; books and records issues; and other misconduct. It resulted in voluntary disclosure to the SEC and DOJ, numerous employee terminations, company restructuring, hiring of new compliance personnel, and an enhanced compliance program and oversight. The SEC and DOJ issued simultaneous declinations.