Stanley Black & Decker voluntarily disclosed to federal regulators its international division might have violated the Foreign Corrupt Practices Act (FCPA).
In its annual report published Thursday, the Connecticut-based tool manufacturer said it “identified certain transactions relating to its international operations that may raise compliance questions under the [FCPA].”
The company said it voluntarily disclosed the information to the Department of Justice (DOJ) and the Securities and Exchange Commission. Stanley Black & Decker said it is “cooperating with both agencies in their investigations” and has hired professional advisers to review and further enhance “relevant policies, procedures, and controls.”
The company did not disclose in what country or countries the potential FCPA violation or violations might have occurred or any further information.
The fact Stanley Black & Decker made the disclosure voluntarily might indicate the DOJ’s enhanced incentives for self-reporting corporate misconduct, including FCPA violations, are bearing fruit.
The agency published its new voluntarily corporate self-disclosure policy Feb. 22 after months of public statements and speeches by officials discussing the changes and the rationale behind them.
The policy changes built on previously announced incentives for companies that voluntarily disclose white-collar crime violations, cooperate with DOJ investigators, and remediate the issues that contributed to or allowed the misconduct. The policy is based on a September 2022 directive from Deputy Attorney General Lisa Monaco, known as the Monaco Memo, which laid out revisions to the agency’s corporate criminal enforcement policies.
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