SEC and DOJ Issue Simultaneous Declinations for Telecom Supplier

The audit committee of a U.S. public telecommunications supplier engaged Faegre Drinker to lead a FCPA investigation focused on third-party intermediaries; gift, travel and entertainment practices; dealings with regulatory authorities for product certification; and various books and records issues involving China, Hong Kong, Thailand, South Korea, Malaysia, Singapore and the U.S. The investigation resulted in voluntary disclosures to the SEC and DOJ. Remediation included the forced resignation of the CFO, multiple employee terminations, an overhaul of the compliance program, enhanced oversight and hiring of new key personnel. The SEC and DOJ issued simultaneous declinations as a result.