Declinations for communications technology company involving self-enrichment scheme
We secured declinations from the SEC and DOJ following our client’s internal investigation
Davis Polk successfully secured a pair of declinations for a communications technology company in connection with an internal investigation into allegations of a bribery and self-enrichment scheme involving former employees in China. After the company shared the investigation results with the Securities and Exchange Commission and Department of Justice, both agencies declined to bring enforcement actions. This is the second matter in which Davis Polk has secured a declination for this company in the last five years.
The Davis Polk team included partners Greg D. Andres, Angela T. Burgess, Fiona R. Moran and Patrick S. Sinclair and counsel Bo Huang and Yuan Zheng. Members of the Davis Polk team are based in the New York, Washington DC and Hong Kong offices.