Packaging Supplier Completes Internal FCPA Investigation and Voluntary Disclosure

A packaging supplier engaged Faegre Drinker to conduct an internal FCPA investigation of a China subsidiary’s dealings with government regulators and employees of state-owned enterprise customers in the month prior to the company’s initial public offering (IPO). We worked with the client’s IPO counsel to devise a strategy to address issues while maintaining IPO timeline and outcome, resulting in the client successfully launching its IPO on schedule and as planned, immediately preceded by our making voluntary self-disclosure on client’s behalf to the DOJ and SEC. The DOJ issued a closure letter in April 2021.