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ARTICLE · 29 JULY 2019

Microsoft And Subsidiaries Settle Charges For Violating FCPA

Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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A global technology company and its subsidiary settled SEC and DOJ charges for violating the books and records, and internal accounting controls provisions of the Foreign Corrupt Practices Act ("FCPA").

United StatesCriminal Law

A global technology company and its subsidiary settled SEC and DOJ charges for violating the books and records, and internal accounting controls provisions of the Foreign Corrupt Practices Act ("FCPA").

According to the DOJ, an executive and several other employees of a Hungarian subsidiary of Microsoft Corporation ("MS Hungary"), along with third parties acting on MS Hungary's behalf, participated in a bid-rigging and bribery scheme. Specifically, MS Hungary sold software licenses through third parties acting on its behalf, charging significantly discounted rates by falsely representing to the Microsoft Business Desk that the discounts were required for government customers. The DOJ stated that the false discounts created inflated margins for the third parties, which then were used for improper payments in violation of the FCPA.

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