資料來源：The FCPA Blog By Harry Cassin | Wednesday, December 26, 2018 at 6:48PM

寶利通為中國的賄賂達成了1600萬美元的FCPA和解協議
Polycom reaches $16 million FCPA settlement for China bribes
American communication technology provider Polycom Inc. settled FCPA books and records and internal accounting controls provisions charges with the SEC Wednesday for using resellers and distributors in China to bribe government officials.

Polycom agreed to disgorge to the SEC about $10.7 million and pay prejudgment interest of $1.8 million, along with a penalty of $3.8 mllion. The company didn't admit or deny the SEC's findings.

The SEC resolved the case through an internal administrative order (pdf) without going to court.

The DOJ also released a "declination with disgorgement" with Polycom that was dated December 20. The declination (pdf) required Polycom to disgorge about $31 million overall to resolve "bribery committed by employees of the Company’s subsidiaries in China." The DOJ said the China subsidiaries also knowingly and willfully caused false books and records at Polycom.

Under the declination, Polycom disgorged $10.8 million to the SEC, as well as $10.15 million to the U.S. Treasury Department and $10.15 million to the U.S. Postal Inspection Service Consumer Fraud Fund.

In return, the DOJ said it "declined prosecution consistent with the FCPA Corporate Enforcement Policy."

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資料來源：The FCPA Blog By Harry Cassin | Wednesday, December 26, 2018 at 6:48PM

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