In October 2024, the Securities and Exchange Commission (SEC) announced a settlement with Moog, Inc., a U.S.-based aerospace and defense company, for violating the Foreign Corrupt Practices Act (FCPA).
In an article for the Anti-Corruption Report, litigation & enforcement partner Geoffrey Atkins commented on the broader implications of the settlement, highlighting its significance for subsidiary liability, third-party risk, and self-reporting. Geoffrey noted that while "the infractions appeared minor, and the connection of the Moog parent entity to the misconduct was fairly attenuated…still, Moog paid a penalty, albeit a modest one."
Geoffrey emphasized the importance of robust compliance programs, especially given the pandemic's impact on organizational culture. "During the pandemic, it became difficult to ensure that compliance culture permeated every office or geography," he said, underscoring the need "for a business’s leaders across functions, including sales and commercial functions, to openly demonstrate a commitment to compliance as a priority.”
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