Juniper Networks, a networking and cybersecurity solutions company, has settled FCPA accounting provisions charges brought by the SEC. The problems stemmed from misconduct at Chinese and Russian subsidiaries involving leisure trips for customers, including some government officials, funded by off-the-books accounts and sometimes masked with the use of falsified meeting agendas. The settlement highlights the continuing risks associated with third parties, discounts, travel and entertainment, particularly for an industry that, as Facebook’s motto used to say, likes to move fast and break things. But there are lessons here for everyone, commentators said, starting with how the SEC will hold a company to its written policies and the dangers of ineffective remediation. See our three-part series on managing subsidiary risks: “Setting Things Up for Success” (Mar. 29, 2017); “Culture and Communication” (Apr. 12, 2017); and “Internal Controls” (Apr. 26, 2017).