The FCPA enforcement world is littered with companies that literally purchased an FCPA violation because they failed to engage in post-acquisition integration of the acquired entity. Probably the seminal enforcement action is the eLandia matter. In June 2007, the company acquired Latin Node, which provided wholesale telecommunications services to several developing countries by leasing lines from local phone companies, in Latin America for $20 million. In August 2007, during a post-acquisition financial integration review, eLandia discovered evidence that Latin Node had paid approximately $2.25 million in bribes to Honduran and Yemeni government officials between March 2004 and June 2007. Subsequently, eLandia voluntarily reported the payments to the Justice Department, eventually paying a $2 million fine and placing Latin Node into bankruptcy and thereby losing its entire investment.
