Toronto-based Kinross Gold Corporation recently agreed to a $950,000 penalty and settled with the SEC over alleged FCPA violations associated with failure to implement accounting controls at two African subsidiaries. Notably, the company had conducted due diligence before acquiring the subsidiaries. But, despite learning that there was no anti-corruption program and associated accounting controls in place, Kinross Gold operated its mines without developing and maintaining an adequate system of internal accounting controls. The Anti-Corruption Report talked to practitioners about the implications of the deal for other companies, in the extractive industries and beyond. See “Structuring M&A Transactions to Minimize Corruption Risk” (Oct. 18, 2017), “Mitigating Corruption Risk When Acquiring Companies in High-Risk Jurisdictions” (May 24, 2017) and  “How to Mitigate FCPA Risk Before and After an Acquisition” (Feb. 18, 2015).