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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

What FCPA-related investigations are we tracking in Ukraine?

When Russia began its invasion of Ukraine in February, four issuers had disclosed ongoing FCPA-related investigations that involved alleged conduct in Ukraine. Three of the companies are based in the United States and one in India.

According to data compiled by FCPA Tracker from companies and enforcement agencies, IBM disclosed another investigation involving Ukraine. That investigation ended with DOJ and SEC declinations in 2017.

FCPA Tracker typically follows more than 100 open FCPA-related investigations. Current open investigations involve at least 48 different countries.

The companies with open Ukraine-related investigations represent various industries, including pharmaceuticals, climate control, and food production.

The most recent investigation was first disclosed in early 2021. The company said in an SEC filing it was triggered by “an anonymous complaint.”

The longest-running open investigation involving Ukraine was first disclosed in 2014, according to data from FCPA Tracker.

Two of the open investigations also involve alleged conduct in Russia.

Three FCPA enforcement actions have involved Ukraine. Teva Pharmaceuticals Industries in 2016, Analogic Corporation also in 2016, and Archer Daniels Midland Company in 2013. Allegations against Teva Pharmaceuticals and Analogic also involved conduct in Russia.

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