Chemical Company Defending Two-Phased FCPA Investigation

A public U.S. multinational chemical company engaged Faegre Drinker to undertake a two-phased FCPA investigation into allegations arising from a whistleblower complaint and derivative issues involving the company’s Chinese subsidiary. The investigation addressed alleged conflicts of interest, improper use of third-party intermediaries, questionable sales practices involving state-owned enterprises, books and records issues, and misuse of tax invoices. The matter concluded with employee and third-party intermediary remediation, an enhanced vendor due diligence, contracting and oversight program and our recommendation of no voluntary disclosure.