For the first time, the Securities and Exchange Commission has brought an FCPA enforcement action premised entirely on a one-time charitable contribution.
On September 20, 2016, the SEC announced a settled FCPA enforcement action against Nu Skin Enterprises, Inc. (Nu Skin US) premised on its subsidiary’s one-time contribution to a charity associated with a Chinese Communist Party Official. The SEC framed the conduct as a violation of the FCPA’s internal controls and books and records provisions.
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