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Podcast: Corruption Crime & Compliance
Episode: Episode 104 -- Deep Dive into the Microsoft FCPA Settlement
Description:
On July 22, 2019, Microsoft finally resolved its FCPA enforcement action with a whimper. Notwithstanding prior suggestions that Microsoft’s investigation uncovered global conduct, Microsoft’s liability focused primarily on Microsoft’s conduct in Hungary. Even with the tailored settlement agreement, DOJ and the SEC reiterated robust expectations surrounding third-party distributor networks, particularly in the software industry.
To resolve a lengthy six and one-half year investigation, Microsoft entered into a non-prosecution agreement with the Justice Department and an administrative settlement with the SEC. Under the three-year NPA, a Microsoft subsidiary in Hungary, Microsoft Magyar...