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Issues To Consider From The Philips Enforcement Action


This recent post highlighted the approximate $62 million Foreign Corrupt Practice Act enforcement action against Philips based on conduct in Angola. By resolving another FCPA enforcement action, Philips joined the corporate FCPA repeat offender club.

This post highlights additional issues to consider.


As highlighted in this prior post, Philips had been under FCPA scrutiny since at least June 2019.

Thus, from start to finish, the company’s FCPA scrutiny lasted approximately four years.

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Philips Joins The Corporate FCPA Repeat Offender Club


The Foreign Corrupt Practices Act corporate repeat offender club is getting so large, that it really is not all that exclusive.

In 2013, Koninklijke Philips Electronics N.V. (“Philips”), a Netherlands-based company with shares listed on the New York Stock Exchange, resolved a $4.5 million FCPA enforcement action concerning conduct in Poland. (See here for the prior post).

In resolving the matter, Philips consented to entry of the Order prohibiting future FCPA violations.

Yesterday, the SEC announced that Philips agreed to pay “more than $62 million to resolve charges that it violated the FCPA” with respect to conduct related to its sales of medical diagnostic equipment in China.”

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Scrutiny Alerts

scrutiny alert


As highlighted in this prior post, in mid-2019 Honeywell disclosed that it was cooperating with the DOJ/SEC and Brazilian law enforcement investigations relating to its use of third parties in relation to Petrobras business as well as a matter involving a foreign subsidiary’s prior engagement of Unaoil in Algeria.

Honeywell recently disclosed: “We have begun discussions with the authorities with respect to a potential resolution of these matters. As the discussions are ongoing, there can be no assurance as to whether we will reach a resolution with such authorities or as to the potential timing, terms, or collateral consequences of any such resolution. As a result, we cannot predict the outcome of these matters, the potential impact on the Company, or a reasonable estimate of losses or range of losses at this time.”

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FCPA Scrutiny Of Philips Grows


As highlighted in this prior post, in 2013 Philips (a Netherlands-based company with shares listed on the NYSE) resolved a $4.5 million Foreign Corrupt Practices Act enforcement action concerning conduct in Poland.

As highlighted in this prior post, in 2019 the company again became the subject of the FCPA scrutiny – this time concerning conduct in Brazil and China.

As highlighted below, Philips recently disclosed that its conduct in another country is also under scrutiny.

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