Background

A Korean company will pay $6.3 million to the Securities and Exchange Commission to resolve charges that it violated the Foreign Corrupt Practices Act by providing improper payments for the benefit of government officials in Korea and Vietnam. This amount includes $3.5 million in civil penalties and $2.8 million in disgorgement.

According to an SEC press release, the Korean company lacked sufficient internal accounting controls over charitable donations, third-party payments, executive bonuses, and gift card  purchases. As a result, the company’s employees, including high-level executives, were able to generate slush funds used for gifts and illegal political contributions to government officials in Korea who had influence over the company’s business. Other employees were able to make payments in connection with seeking business from government customers in Vietnam.

The company and 14 of its executives were indicted in Korea in November 2021 for criminal violations related to illegal political contributions from the slush funds.

For more information on the FCPA, please contact Kristine Pirnia at (202) 730-4964 or via email.

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