FCPA allegations can have wide-ranging collateral consequences, even before the resolution of an enforcement action.  One such consequence is a civil lawsuit like the one Avon, a company that has conducted an extensive and costly corruption investigation, was facing in federal court in New York.  Avon has successfully moved to dismiss that civil case brought by shareholders who alleged that they were misled by the company and two of its former senior executives.  They claimed the company misrepresented the efficacy of Avon’s compliance program and touted Avon’s sales successes in China without revealing that those successes stemmed from bribery.  We analyze the case and the judge’s reasoning.  See also “Non-FCPA Liability for Alleged FCPA Violations” (Jun. 6, 2012).