Harris Corp., a Florida-based international communications and information technology company, found an unwelcome surprise after it purchased CareFx Corp. During a post-acquisition audit in 2012, Harris discovered that the Chinese division of its new subsidiary was engaged in an ongoing bribery scheme. Harris reported the wrongdoing to the SEC and DOJ, cooperated and remediated and subsequently avoided civil and criminal FCPA charges, while the former CEO of the Chinese subsidiary settled charges with the SEC for $46,000. The SEC asserted that the former CEO condoned the bribery scheme and failed to disclose it to Harris. “[F]or the first time in a case involving only FCPA misconduct, the authorities have given a large public multinational company a full declination after charging a former employee with FCPA violations that, on their face, would have resulted in the past in a multi-million dollar enforcement action against the company,” Robert Kent, a partner at Baker & McKenzie and lead counsel for Harris in the CareFx China investigation, told the Anti-Corruption Report. See also “PetroTiger’s Counsel Reveals the Defense Strategy That Led to a DOJ Declination” (Jul. 22, 2015).