Tagged: India bribery

Beam Suntory Bribery Scheme: Another Controls Failure (Part II of II)

The Beam Suntory case is yet another example of a failure of internal and external auditors, and legal and compliance professionals.  Reviewing cases involves a focus on how and why a compliance failure occurred.  In many cases, legal, compliance and internal auditors are being shunned, ignored, or subjected to pressure to keep their mouths shut or agree to go forward with otherwise problematic transactions or...

DOJ Hits Beam Suntory with FCPA Settlement for $19.5 Million (Part I of II)

Beam Suntory, a global producer and distributor of distilled beverages, settled its FCPA case with DOJ for $19.5 million for bribes paid in India.  The DOJ settlement follows an SEC FCPA settlement for $8 million announced on July 2, 2018.  The timing of the FCPA settlements is unusual and suggests that DOJ’s resolution involved unique issues relating to Beam Suntory’s cooperation.  The SEC resolution was...

The Anatomy of a Bribery Scandal: Digging into the Cognizant Bribery Scheme (Part II of IV)

The Cognizant bribery scheme is another in the line of illegal conspiracies orchestrated by senior management – but this one is even more disturbing for a number of reasons.  Cognizant’s former president and general counsel directed the scheme in full consultation and with full knowledge and intent with the chief operating officer and the vice president of administration.  Add Cognizant to the list of companies...

Beam Settles FCPA Violations with SEC for $8 Million for Pervasive Third-Party Bribery Schemes

After a lengthy investigation conducted by the SEC, Beam Suntory agreed to pay $8 million to settle FCPA violations in India.  (Copy of SEC order Here).  Beam’s settlement took over 5 years from initial disclosure to resolution – a long-time to say the least.  Interestingly, there has been no resolution or mention of a parallel DOJ investigation. Beam’s conduct follows similar conduct by other liquor companies...