After a lengthy investigation, Dun and Bradstreet (D&B) settled an FCPA enforcement action with the Securities and Exchange Commission for $9 million. (Here). At the same time, the Justice Department issued a declination letter, representing the first written declination under its new Corporate FCPA Enforcement Policy. (Here). D&B’s FCPA violations in China represent the perfect trifecta of risks and violations facing companies in China. The...
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