The John Deere’s FCPA Case: A Throwback to Compliance Fundamentals
In corporate compliance, some very basic compliance lessons are destined to be repeated. This was clear from the recently announced Securities and Exchange Commission (SEC) Foreign Corruption Practices Act enforcement action involving Deere (John Deere herein). The $9.9 million settlement between John Deere and the SEC involved FCPA violations at its Wirtgen Group subsidiary. It offers a stark reminder that even the most established companies can stumble over basic compliance principles . For those in the compliance community, this case highlights the importance of robust integration post-acquisition and serves as a throwback to classic FCPA pitfalls that should have been avoided. The John Deere Case: A Synopsis According to the SEC Press Release announcing the resolution, “From at least late 2017 through 2020, Wirtgen Thailand employees bribed Thai government officials with the Royal Thai Air Force, the Department of Highways, and the Department of Rura...