Classic FCPA pitfalls in expanding global business environment
Whitepaper
John Deere FCPA Enforcement Action
What’s in this whitepaper by Tom Fox:
In a striking reminder that even industry giants can stumble over fundamental compliance issues, John Deere, the renowned agricultural equipment manufacturer, reached a $9.9 million settlement with the SEC for FCPA violations. This case, involving bribery at a subsidiary in Thailand, serves as a stark warning to compliance professionals about the perennial importance of robust anti-corruption measures.
The whitepaper delves into the critical lessons learned from this enforcement action, highlighting the need for thorough pre-acquisition due diligence, swift post-acquisition integration and ongoing vigilance in high-risk markets. It explores how seemingly basic compliance oversights — from inadequate gift and entertainment policies to lax internal controls — can snowball into major legal and reputational risks.
Perhaps most importantly, the paper underscores the value of conducting a comprehensive root cause analysis before jumping into remediation efforts. As author and podcaster Tom Fox notes, “Without understanding why these bribes were paid, simply punishing the employees involved or updating internal policies would have been insufficient.”
