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Lessons to be learned from first declination under new FCPA policy

Jaclyn Jaeger | May 8, 2018

The Department of Justice recently issued its eighth public declination in a Foreign Corrupt Practices Act case and the first under its FCPA Corporate Enforcement Policy—an indication that the policy is alive and well. But the case also brings with it a clear warning: The anti-bribery provisions are not the only way to trip over the FCPA.

The Securities and Exchange Commission on April 23 fined commercial data and analytics provider Dun & Bradstreet (D&B) $9 million after FCPA charges arose from misconduct at two of D&B’s indirect subsidiaries in China. According to the SEC, the two Chinese subsidiaries—HDBC and Roadway—made unlawful payments to Chinese officials through third-party agents and kickbacks to obtain otherwise non-public financial statement data that was vital to D&B’s business as a provider of business financial information.

HDBC and Roadway did not accurately reflect these unlawful payments in their books and records, which were then...

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