Goodyear settles SEC’s FCPA charges for $16M – Underscores Importance of Effective Compliance Programs

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30bdf28By Stephanie Gallagher, JD
stephanie.gallagher@corporatecompliance.org

 

 

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Goodyear settled charges by the SEC, holding it accountable for failing to prevent or detect improper payment by its subsidiaries because, according to the SEC, it did not implement adequate FCPA compliance training and controls. Goodyear has commenced disciplinary action against employees who had oversight for failing to ensure that adequate FCPA compliance training and controls were in place at its subsidiaries, and has implemented improvements to its compliance program. These allegations underscore the continued need for companies to conduct proper acquisition due diligence and to maintain strong controls and compliance programs.

However, it is noteworthy that this settlement is much lower than others in recent history, likely because Goodyear promptly cooperated with the SEC investigation. This settlement drives home the importance of implementing a robust compliance program, domestically and abroad, as well as prompt cooperation with investigations. Not only can an effective compliance program save the organization millions of dollars in the event of a violation, proper compliance programs and processes can prevent the violation from occurring in the first place.

More details about the settlement are available here.