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Looking Back At The Young & Rubicam Enforcement Action

Young

Previous posts here and here covered the recent Foreign Corrupt Practices Act enforcement action against WPP plc (the world’s largest advertising group).

An interesting backstory to the WPP enforcement action is that in 2000 WPP merged with Young & Rubicam Inc. pursuant to which Y&R joined the WPP group of companies (see here).

For FCPA history buffs, in 1989 Y&R (along with executives Arthur Klein, Thomas Spangenberg and others) were charged with FCPA violations. (See here for the prior post).

As repeated below, it was, and remains, one of the most interesting FCPA enforcement actions of all time.

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Issues To Consider From The WPP Enforcement Action

Issues

This previous post highlighted the recent $19.2 million SEC Foreign Corrupt Practices Act enforcement action against London-based advertising agency WPP (a company with depositary shares traded on the New York Stock Exchange).

This post continues the analysis by highlighting additional issues to consider.

No Disclosure

Most issuers under FCPA scrutiny tend to disclose the scrutiny in SEC filings and thereafter disclose scrutiny developments in subsequent filings.

However, WPP appears to be a relatively rare example of an issuer not disclosing FCPA scrutiny.

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Bad Advertising – Ad Group WPP Resolves $19.2 Million FCPA Enforcement Action

WPP

Last Friday, the SEC announced that London-based WPP (the world’s largest advertising agency and a company with depositary shares traded on the New York Stock Exchange) agreed to resolve a $19.2 million Foreign Corrupt Practices Act enforcement action.

The enforcement action focused on WPP subsidiary conduct in India, China, Brazil and Peru.

In summary fashion, the SEC’s order finds:

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