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Harry Cassin
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When do issuers disclose their FCPA problems?

During the first half of 2018, seven issuers resolved FCPA offenses with the the DOJ or SEC or both. When did the companies first learn about their potential FCPA offenses, (according to their own disclosures), when did they first disclose the potential offenses, and when did they finally resolve the offenses with the feds?

Here’s what we found:

Elbit Imaging LTD. (Israel) resolved FCPA offenses on March 9, 2018. It first disclosed the FCPA investigation on April 21, 2016. It first discovered the potential offenses in March 2016.

Kinross Gold Corporation (Canada) resolved FCPA offenses on March 26, 2018. It first disclosed the FCPA investigation on October 2, 2015. It first discovered the potential offenses in August 2013.

Dun & Bradstreet Corporation (USA) resolved FCPA offenses on April 23, 2018. It first disclosed the FCPA investigation on March 19, 2012. It first discovered the potential offenses — no date disclosed.

Panasonic Corporation (Japan) resolved FCPA offenses on April 30, 2018. It first disclosed the FCPA investigation on February 2, 2017. It first discovered the potential offenses — no date disclosed.

Société Générale (France) resolved FCPA offenses on June 4, 2018. It first disclosed the FCPA investigation on November 6, 2017. It first discovered the offenses in April 2014.

Legg Mason, Inc. (USA) resolved FCPA offenses on June 4, 2018. It first disclosed the FCPA investigation on May 30, 2018. It first discovered the potential offenses — no date disclosed.

Credit Suisse Group AG (Switzerland) resolved FCPA offenses on July 6, 2018. It first disclosed the FCPA investigation on February 14, 2018. It first discovered the potential offenses — no date disclosed.

We conducted the research for this post on FCPA Tracker.

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Richard L. Cassin is the publisher and editor of the FCPA Blog.

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