Tyco Settles SEC and DOJ Charges Relating to FCPA Violations, Agrees to Pay Over $26 Million in Penalties, and Subsidiary Pleads Guilty to Criminal FCPA Charge

In connection with a 2006 settlement with the SEC over alleged FCPA and other violations, Tyco International Ltd. (Tyco) pursued a comprehensive compliance review of all of its operating entities – 454 companies in 50 countries.  That review disclosed additional FCPA violations, or continuing benefits from prior violations, involving more than a dozen Tyco direct and indirect subsidiaries.  Tyco reported those findings to the SEC and DOJ, which began new investigations into Tyco’s operations.  On September 24, 2012, the DOJ and SEC announced that Tyco has now reached a comprehensive settlement of those new matters, consisting of three separate elements: A settled civil enforcement action by the SEC against Tyco, a non-prosecution agreement between the DOJ and Tyco and the entry of a guilty plea to a criminal violation of the FCPA by a Tyco subsidiary.  This article provides a summary of the various investigations and charges and the details of the three settlements.

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