John Deere Declination
On January 11, 2013, John Deere stated that the SEC would not bring a FCPA action against the Illinois-based company. The investigation by the SEC was based upon 2011 allegations of illegal payments to Russian foreign officials and neighboring Eastern European countries. The SEC required documents pertaining to Deere's activity in Russia and bordering coun-tries to conduct its investigation. Russia is a particularly attrac-tive market for Deere because it holds approximately nine percent of the world's arable land. Deere announced shortly before the investigation that it planned a large expansion and doubling of sales to $50 billion by 2018.
3M Declination
3M reported on February 14, 2013, that both the DOJ and the SEC were declining to pursue a FCPA enforcement action against the company. Both government agencies have been investigating 3M since 2009 over allegations of bribery and bid rigging by its subsidiary in Turkey. 3M self- disclosed to the DOJ and the SEC the results of a prior internal investigation. Turkish authori-ties also declined to take action against 3M, citing insufficient evidence of violations of Turkish competition laws.
Nabor Declination
Houston-based Nabor Industries Ltd. stated on February 20, 2013, that the DOJ will not bring a FCPA enforcement action. Nabor was once a customer of Panalpina, a Swiss-based logistics firm that admitted, in November 2010, to paying bribes to officials to help move their customers' drill rigs and other equipment in and out of countries such as Saudi Arabia, Algeria, and Nigeria. The SEC announced, in November 2012, that it would pursue a FCPA enforcement action against Nabor. The entire investigation lasted around five years.
Zimmer Declination
India-based Zimmer Holdings, Inc. announced on February 28, 2013, that the DOJ and the SEC would not bring a FCPA enforce-ment action against the medical device maker. In 2007, the SEC informed Zimmer that it was conducting an investigation into the company. The DOJ asked Zimmer to provide information on a voluntary basis. In 2011, the SEC subpoenaed Zimmer seeking documents pertaining to sales activities of their opera-tions in the Asia-Pacific region. Zimmer has business locations in China, India, Hong Kong, Taiwan, Thailand, Australia, and New Zealand.
DynCorp Declination
On March 27, 2013, Delta Tucker Holdings stated that the DOJ will not bring a FCPA enforcement action against its wholly-owned subsidiary, DynCorp International, Inc. The DOJ had been investi-gating payments by two subcon-tractors of DynCorp International, Inc. that were used to "expedite the issuance of a limited number of visas and licenses from foreign government agencies." DynCorp first disclosed, in November 2009, awareness of the payments, which totaled $300,000. DynCorp self-disclosed the situation to the DOJ and the SEC.
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