SICPA Accepts Conviction of Corporate Criminal Liability in Connection With Acts of Corruption

On April 27, 2023, SICPA, a Swiss company providing secured identification, traceability and authentication services, acknowledged, with strong caveats, the Swiss government’s position that it failed to take all necessary and reasonable organizational measures between 2008 and 2015 to prevent bribes to foreign public officials. The Office of the Attorney General of Switzerland identified organizational deficiencies that “made it possible for employees of SICPA to bribe public officials in the conduct of business in Brazil, Colombia, and Venezuela.” SICPA said that while it acknowledged the conviction, it disagreed with the grounds, and acquiesced to the conviction because of uncertainty caused by the proceedings. This article explores what compliance practitioners can learn from this case, according to Juerg Bloch and Simon Bühler, attorneys at the Swiss law firm Niederer Kraft Frey, and Anne Valérie Julen Berthod and Joël Pahud, attorneys at the Swiss law firm Oberson Abels. See “No Longer a Slap on the Wrist: SEC Penalties and Sentences on the Rise” (Jan. 18, 2023).​​​​​

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