A&O Shearman FCPA Digest | SEC v. Delta & Pine Land Co. & Turk Deltapine, Inc. (D.D.C. 2007)<br /> In the Matter of Delta & Pine Land Co. & Turk Deltapine, Inc. (2007)

Source Documents

Case Name
SEC v. Delta & Pine Land Co. & Turk Deltapine, Inc. (D.D.C. 2007)
In the Matter of Delta & Pine Land Co. & Turk Deltapine, Inc. (2007)

Nature of Business
Delta & Pine Land Company (“Delta”), a U.S. corporation, is engaged in the breeding, production, and marketing of cottonseed. Turk Deltapine, Inc. (“Turk”) is a wholly-owned, U.S.-based subsidiary of Delta engaged in the production and sale of cottonseed in Turkey. Delta was acquired by Monsanto Company on June 1, 2007.

Influence to be Obtained
Turk made the payments to secure governmental reports and certifications that were necessary for it to operate in Turkey.

Enforcement
On July 25, 2007, the SEC filed a civil complaint against Delta and Turk, alleging both had violated the FCPA. Without admitting or denying the allegations of the complaint, Delta and Turk consented to the entry of a final judgment requiring a $300,000 penalty to be paid jointly and severally by them. On July 26, 2007, the SEC also filed a cease‑and‑desist order against Delta and Turk, finding that Delta had violated the books‑and‑records and internal controls provisions of the FCPA and that Turk had violated the anti‑bribery provisions of the FCPA. The cease‑and‑desist order required Delta to retain an independent consultant to review and recommend improvements to the company’s FCPA compliance policies and procedures. Delta and Turk neither admitted nor denied the allegations of the SEC’s cease‑and‑desist order.

Citation
SEC v. Delta & Pine Land Co. et al., No. 07-cv-1352 (D.D.C. 2007); In the Matter of Delta & Pine Land Co. & Turk Deltapine, Inc., Admin Proc. File No. 3-12712 (2007).

Citation
SEC v. Delta & Pine Land Co. et al., No. 07-cv-1352 (D.D.C. 2007); In the Matter of Delta & Pine Land Co. & Turk Deltapine, Inc., Admin Proc. File No. 3-12712 (2007).