The SEC is having a good year in prosecuting FCPA cases.  The SEC’s recent settlement with 3M Corp. for $6.5 million is its seventh corporate resolution for the year.  DOJ, which has been relatively quiet so far this year, recently resolved the Corficocolombiana case, its first for the year.

3M’s conduct centered on payments for Chinese healthcare officials employed by state-owned enterprises to attend overseas conference, educational events and healthcare facility visits (“educational events”) but which were actually pretexts to provide overseas travel, sightseeing and entertainment (“tourism activities”).

Between 2014 and 2018, a 3M marketing manager in China worked with two China-based travel agencies to provide tourism activities to Chinese healthcare officials during educational events. The 3M marketing manager was assisted in this scheme by several employees in 3M-China’s sales, marketing and professional services.

In this Episode, Michael Volkov reviews the 3M FCPA Settlement with the SEC.