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D&B shows the right way to handle an FCPA probe

Tom Fox | May 15, 2018

Dun & Bradstreet (D&B) in late April resolved a long-standing FCPA investigation with some excellent results. The first was that it received a declination from the Justice Department from prosecution of any criminal matters. It resolved a civil violation with the Securities and Exchange Commission for $9.2 million consisting of a penalty and interest and disgorgement of illegally obtained profits.

While the case had been ongoing since 2012, it was the first major FCPA matter resolved after the implementation of the new FCPA Corporate Enforcement Policy by the Justice Department. This enforcement action presented several important factors that every compliance practitioner can learn from going forward.

From a tactical perspective, D&B ran into FCPA trouble in China, largely through entities it either acquired or was involved in as joint venture partners. The first was HDBC, formed as a joint venture between D&B’s Chinese subsidiary and Huaxia. In the...

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