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Scrutiny Alerts

CHS Inc., an agricultural cooperative, disclosed:

“In the fourth quarter of fiscal 2018, we contacted the U.S. Department of Justice and SEC to voluntarily self-disclose potential violations of the FCPA in connection with a small number of reimbursements the Company made to Mexican customs agents in the 2014-2015 time period for payments the customs agents made to Mexican customs officials in connection with inspections of grain crossing the U.S.-Mexican border by railcar. We are fully cooperating with the government, including with the assistance of legal counsel, which assistance includes investigating other areas of potential interest to the government. We are unable at this time to predict when our or the government agencies’ review of these matters will be completed or what regulatory or other outcomes may result.”

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Laureate Education, A So-Called “B Corp,” Discloses FCPA Scrutiny


One reason to read FCPA Professor is to stay ahead of the curve.

For instance, this November 2015 post titled “FCPA Risks on Campus” discussed how in recent years several U.S. higher education institutions have opened foreign campuses (either directly or through affiliates) in places such as China, India and the Middle East. It was noted that relevant government approvals, licenses, permits, certifications and the like of doing so are really no different than a company needing government approvals to establish a manufacturing presence in a foreign country.

Few higher education institutions are for-profit companies (much less issuers) but Laureate Education Inc. is and earlier this week, the company made a disclosure in this SEC filing about an $18 million (US) charitable donation in Turkey. As an aside, in October 2015 Laureate became a so-called B corporation (a public benefit corporation) and the below disclosure may be the first FCPA related disclosure by a B corp.

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