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SEC Finds That Former Panasonic Executive Authorized Conduct Causing Company’s FCPA Violations, Another Former Executive Found To Engage In Improper Revenue Recognition Practices


As highlighted in prior posts (here, here and here) in April 2018 the DOJ and SEC announced a $280 million Foreign Corrupt Practices Act enforcement action against Japan-based Panasonic Corp.  and a U.S. subsidiary Panasonic Avionics Corp. (PAC).

In the words of the government “between 2007 and 2013, PAC employees, including senior executives, engaged in a scheme to retain consultants for improper purposes other than for providing actual consulting services.”

Earlier this week, the SEC returned to the same core conduct to bring administrative actions (here and here) against Paul Margis (pictured – a former President and CEO of PAC) and Takeshi Uonaga (PAC’s former CFO). The Margis action finds that he authorized various conduct giving rise to the company’s FCPA liability, whereas the Uonaga matter is materially different in that it is a revenue recognition matter.

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Gaining Access To Confidential Documents In The Government’s Possession Is Often The End Result When Things Of Value Are Offered Or Provided To “Foreign Officials”


In several Foreign Corrupt Practices Act enforcement actions, the end result of things of value being offered or provided to alleged “foreign officials” is the company gaining access to confidential documents in the government’s possession.

Which ones?

As highlighted below, with FCPA Professor’s premium search function, the answer can be found in about 5 minutes.

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