ANTICORRUPTION DEVELOPMENTS –

Dun & Bradstreet Agrees to Pay More than $9.2 Million to Resolve SEC FCPA Enforcement Action (But First to Receive Declination Under New DOJ Policy) –

On April 23, the Dun & Bradstreet Corporation (“D&B”), a New Jersey-based provider of business information, submitted an Offer of Settlement to the Securities and Exchange Commission (SEC), resulting in an administrative Cease-and-Desist Order resolving the government’s investigation of alleged violations of the Foreign Corrupt Practices Act (FCPA).

Specifically, the SEC’s enforcement action alleges that, from 2006 through 2012, subsidiaries of D&B made improper payments in order to obtain or retain business. The first subsidiary is D&B’s China-based Dun & Bradstreet International Consultant (Shanghai) Co. Ltd. (“D&B China”). In 2006, D&B China formed a joint venture with Huaxia International Credit Consulting Co. Limited (“Huaxia”) called “HDBC.” According to the SEC’s enforcement action, until mid-2012, HDBC continued Huaxia’s practice of utilizing third parties to make improper payments to officials within China’s State Administration for Industry and Commerce (AIC) to acquire business information that would not otherwise have been publicly available.