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“Such Conduct Has Occurred With Respect To Certain Contracts”


Raytheon (which changed its name to RTX in 2003) has been under Foreign Corrupt Practices Act scrutiny for several years.

The company recently disclosed:

“As previously disclosed, in 2019, Raytheon Company received a subpoena from the Securities and Exchange Commission (SEC) seeking information in connection with an investigation into whether there were improper payments made by Raytheon Company, our joint venture known as Thales-Raytheon Systems (TRS), or anyone acting on their behalf, in connection with TRS or Raytheon Company contracts in certain Middle East countries since 2014. In the first quarter of 2020, the DOJ advised Raytheon Company it had opened a parallel criminal investigation. In the third quarter of 2020, Raytheon Company received an additional subpoena from the SEC, seeking information and documents as part of its ongoing investigation. The Company maintains a rigorous anti-corruption compliance program, and continues to cooperate fully with the SEC’s and DOJ’s inquiries, and to examine through our own investigation whether there were any improper payments or any such conduct that was in violation of Raytheon Company policy.

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Scrutiny Updates

scrutiny alert

Remember when a top-ranking DOJ official said in 2017 (see here) that the DOJ’s “intent is for our FCPA investigations to be measured in months, not years”?

Me too. That was pretty funny.

Set forth below are scrutiny updates from companies that have been under FCPA scrutiny for approximately three years.


As highlighted here, Pfizer (a company that resolved a $60 million FCPA enforcement action in 2012 concerning conduct in Bulgaria, China, Croatia, Czech Republic, Italy, Kazakhstan, Russia, and Serbia) disclosed additional FCPA scrutiny in mid-2019.

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Scrutiny Alerts And Updates

scrutiny alert

This post highlights a new instance of Foreign Corrupt Practices Act scrutiny involving KT Corporation (a South Korean telephone company) and updates regarding long-standing FCPA scrutiny of Herbalife, World Acceptance Corp., Raytheon, and Stericyle.

KT Corporation

For several years, KT Corp (South Korea’s largest telecom company with shares traded on the New York Stock Exchange) has been under scrutiny by South Korean authorities for, among other things: donations to non-profit foundations at former President Park’s request; making certain donations or gifts to various lawmakers; and alleged improper hiring of college graduates.

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