American multinational conglomerate 3M entered into an agreement with the SEC on August 25, 2023, to resolve charges it violated the internal accounting controls and books and records provisions of the FCPA by allegedly plying Chinese officials with travel and leisure activities to induce them to purchase 3M products. The SEC order alleges that 3M’s Chinese subsidiary paid nearly $1 million to fund trips for Chinese government officials that included these activities. Without admitting or denying the findings, 3M agreed to avoid future violations of these provisions and pay disgorgement plus prejudgment interest and a civil penalty totaling $6.5 million. The Anti-Corruption Report spoke with Samantha Badlam, a partner at Ropes & Gray, to find out what compliance practitioners should take away from this case and best practices to incorporate into business courtesies programs. See “Travel Agency Abuse, Falsified Expense Reports and Other Hospitality Blunders Lead to $25 Million Novartis Settlement” (Apr. 6, 2016).