Lifecore Resolves FCPA Enforcement Action Regarding Wastewater Issues In Mexico
Yesterday, the DOJ released this so-called “declination with disgorgement” letter regarding Lifecore Biomedical, Inc. (f/k/a Landec Corporation) in connection with alleged Foreign Corrupt Practices Act violations involving wastewater issues in Mexico.
Pursuant to the letter agreement, Lifecore agreed to “disgorge” $406,505 in “costs avoided” (which of course is an interesting spin on disgorgement which is traditionally understood to mean relinquishment of unjust gains).
The letter agreement states in full: