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...