Jenner & Block

Panasonic and Subsidiary Panasonic Avionics Corporation Pay Over $280 Million in Penalties and Disgorgement to Resolve Foreign Corrupt Practices Act and Accounting Fraud Violations

On April 30, 2018, multinational electronics company Panasonic Corporation (“Panasonic”) and its US subsidiary Panasonic Avionics Corporation (“PAC”) agreed to pay the US Department of Justice (“DOJ”) and the US Securities and Exchange Commission (“SEC”) over $280 million in penalties, disgorgement, and pre-judgment interest to resolve Foreign Corrupt Practices Act (“FCPA”) and accounting fraud violations, making this the largest FCPA settlement so far this year.  Specifically, PAC entered a  deferred prosecution agreement  (“DPA”) with DOJ to resolve violations of the FCPA’s books and records provisions; separately, Panasonic agreed to an SEC cease-and-desist order finding violations of the FCPA’s anti-bribery, books and records, and internal controls provisions, as well as securities reporting requirements.  The violations arose out of schemes by PAC to retain consultants for improper purposes, conceal payments to sales agents, and improperly recognize revenue.

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