September 30, 2018

This month, the SEC issued two consensual cease-and-desist orders to resolve FCPA violations.

One ordered against Sanofi for violations stemming from bribery schemes involved subsidiaries based in Kazakhstan, Lebanon, and the UAE. The order directed disgorgement, interest and a civil penalty totaling over US$25 million.

United Technologies Corporation was also issued a cease-and-desist order for violations stemming from bribes paid on behalf of its subsidiaries in Azerbaijan and China and improper travel and entertainment expenses for officials in various countries. The order directed disgorgement, interest and a civil penalty totaling nearly US$14 million.

Visit the TRACE Compendium to view the complete entries, along with other updates from this month.