[Audio] Episode 338 -- Deep Dive into the Deere SEC FCPA Case
JD Supra: Mergers
SEPTEMBER 29, 2024
The SEC's recent settlement with Deere & Company for $9.9 million for FCPA violations is another textbook example of bribery schemes, which revealed the absence of a culture of compliance, and the circumvention of basic entertainment, hospitality and travel expense controls. Deere's bribery scheme involved its Thailand subsidiary, Wirtgen Thailand, and various improper payments to government officials, including cash, sham consulting fees, extravagant “factory visit” trips to foreign.
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