Issues To Consider From The Moog Enforcement Action

This previous post highlighted the $1.7 million Foreign Corrupt Practices Act enforcement actions against Moog Inc. concerning subsidiary conduct in India.

This post highlights additional issues to consider.

No Prior Disclosure

It is rarely a surprise when a publicly-traded company (an issuer under FCPA speak) resolves an FCPA enforcement action because most issuers disclose FCPA scrutiny in an SEC filing.

Moog Inc. Resolves $1.7 Million FCPA Enforcement Action Based On Indian Subsidiary Conduct

Moog Inc. (“Moog”) is a worldwide designer and manufacturer of motion controls systems for a broad range of applications in aerospace, defense, industrial and medical markets. The New York headquartered company – with four operating segments: military aircraft, commercial aircraft, space and defense, and industrial – has shares traded on the New York Stock Exchange and has sales, engineering, and manufacturing facilities in twenty-six countries.

Moog is the latest company to resolve a Foreign Corrupt Practices Act enforcement action.