From the FCPA Blog members area, here’s Embraer S.A.’s FCPA disclosure in its SEC filing on October 24:
We, through our outside counsel hired to respond to the SEC-issued subpoena and associated inquiries into the possibility of non-compliance with the U.S. Foreign Corrupt Practices Act, or FCPA, continue to cooperate fully with the SEC and U.S. Department of Justice, or DOJ, in their investigation of such matters. As part of the cooperation, our outside counsel has reported to the SEC and DOJ with respect to its internal investigation, which is continuing, and has provided information requested by, and responded to questions from, the SEC and DOJ. The SEC and DOJ investigations continue, and our management, with the support of our outside counsel, continues to believe that it is not possible to estimate the duration, scope or results of the investigations. In the event that the SEC and/or DOJ investigations result in enforcement action, we may be required to pay substantial fines and/or to incur other sanctions, as provided in the FCPA. Our management, based upon the opinion of our outside counsel, continues to believe that there is no basis for estimating reserves or quantifying any possible contingency.
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