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Jan. 9, 2019

Polycom Settles Chinese Bribery Charges With SEC, but DOJ Declination Accounts for Most of the Disgorgement 

  • Rebecca Hughes Parker
    Anti-Corruption Report
A bribery scheme allegedly carried out by communications product company Polycom in China through a shadow books-and-records system has led to a $16.3-million settlement with the SEC and a declination by the DOJ that carried a $20.3-million disgorgement price tag. The case, involving discounts given to foreign officials through a distributor from 2006 to 2014, reveals the effect of a potentially weak tone from the top, how Kokesh may affect FCPA resolutions and how the Corporate Enforcement Policy’s declination policy is working in practice. See “The DOJ’s FCPA Corporate Enforcement Policy One Year Later” (Dec. 12, 2018).

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