Background

A U.S. electronic products company announced recently that it will pay $36 million to settle charges that a firm it acquired in 2018 violated the Foreign Corrupt Practices Act. According to a Wall Street Journal article, this amount includes roughly $10.7 million in disgorgement, a civil penalty of $3.8 million, and $1.8 million interest to be paid to the Securities and Exchange Commission. In addition, the article states, the company agreed to disgorge another $20.3 million as part of a deal under which the Department of Justice declined further prosecution.

A company press release states that after discovering evidence of possible improper behavior on the part of former employees at its subsidiary in China, the acquired company voluntarily reported the matter to the U.S. government, conducted a thorough investigation, and fully cooperated with U.S. authorities. The press release adds that the conduct at issue was limited to the subsidiary in China and occurred prior to the acquisition, by which time all of the individuals involved had left the acquired company.

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