The FCPA Corporate Investigations List — China Edition (June 2016)

The volunteer researcher who compiles the FCPA Blog’s Corporate Investigations List also tabulated the companies that have mentioned China as part of an ongoing FCPA investigation.

There are 24 companies on this China Edition of the Corporate Investigations List.

(A total of 84 companies appear on the latest Corporate Investigations List.)

This China Edition is current as of March 31, 2016.

Two companies on the list — Las Vegas Sands and Nortek — resolved FCPA enforcement actions since March 31, 2016. Akamai also resolved an enforcement action related to China. Although it disclosed an FCPA investigation it didn’t name China as the country involved. So it doesn’t appear on this list.

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Here are the 24 companies as of March 31, 2016 that have mentioned China as part of an on-going FCPA investigation:

1.. AstraZeneca PLC
2.  Delphi Automotive PLC
3.  Deutsche Bank AG
4.  General Cable Corporation
5.  GlaxoSmithKline PLC
6.  Goldman Sachs Group Inc
7.  Grifols SA
8.  Harris Corporation
9.  HSBC
10. Johnson Controls Inc
11. JPMorgan Chase & Co
12. Las Vegas Sands Corp**
13. MTS Systems Corporation
14. NCR Corporation
15. Nortek Inc**
16. Nu Skin Enterprises Inc
17. Rolls Royce PLC
18. Sanofi SA
19. Sensata Technologies Holding NV
20. SL Industries Inc
21. The Dun & Bradstreet Corporation
22. United Technologies Corporation
23. Wal-Mart Stores Inc
24. Wynn Resorts Limited

** Settled FCPA enforcement actions since March 31, 2016

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Preparing this list isn’t easy. Here’s a note from the volunteer researcher about the process:

All of these companies listed have disclosed investigations and appear on the latest Corporate Investigations List. Not all of these companies have disclosed investigations in China, but for those five that haven’t disclosed they are widely reported to be under investigation in China.

Deutsche Bank, HSBC, and JP Morgan all describe “Asia-Pacific” investigations.

Goldman doesn’t disclose the location, but again is reported to be under investigation in China.

Roll-Royce is the only non-financial company on the five but again widely reported to be under investigation in China.

There was one company I decided shouldn’t be reported as China — ABM Industries. They acquired a company under investigation that has operations in China but also operates in other places — hence the investigation could be focused elsewhere. So to be safe I’m not counting it in the statistics of Chinese investigations.

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Richard L. Cassin is the publisher and editor of the FCPA Blog. He’ll be the keynote speaker at the FCPA Blog NYC Conference 2016.