SEC v. The Dow Chemical Co. (D.D.C. 2007)
Case Details
- Case Name
- SEC v. The Dow Chemical Co. (D.D.C. 2007)
- Foreign Official
- An official of the Indian Central Insecticides Board and a variety of other governmental officials, including excise tax officials, sales tax officials, government business officials, and customs officials.
- Date of Conduct
-
1996 to 2001
- Nature of Business
- The Dow Chemical Company (“Dow”), a U.S. corporation, manufactures and sells chemicals, plastics, and agricultural and other products.
- Influence to be Obtained
- From 1996 until 2001, DE‑Nocil Crop Protection Ltd. (“DE‑Nocil”), a Dow subsidiary, made payments to a variety of Indian governmental officials, including payments to an official in India’s Central Insecticides Board to expedite the registration of DE‑Nocil products. The payments were made through contractors, sometimes using false invoices or fictitious charges in bills.
- Enforcement
- On February 13, 2007, the SEC filed a settled civil action against Dow under the FCPA, alleging violations of both its internal controls and its books and records provisions. The SEC also concurrently filed a cease‑and‑desist order against Dow, finding that Dow had also violated the corresponding provisions of the ‘34 Act. Without admitting or denying any of the foregoing allegations, Dow consented to pay a $325,000.00 civil penalty for its violations of the FCPA and consented to the entry of the cease‑and‑desist order under the ‘34 Act
- Amount of the Value
- Approximately $2,000.
- Amount of Business Related to Payment
- Not Stated
- Intermediary
- Third-party contractors
- Citizenship of Parent Entity
- United States
- Reporting Requirements
- No
- Total Combined Monetary Sanction
- $ 35,000
Defendants
The Dow Chemical Co.
- Citation
- SEC v. Dow Chemical Co., No. 07-cv-00336 (D.D.C. 2007).
- Other Statutory Provision
- None
- Disposition
- Complaint and Consent Order
- Defendant Jurisdictional Basis
- Issuer
- Defendant's Citizenship
- United States
