On April 30, 2018, DOJ officials announced that Panasonic Avionics Corp. (“PAC”), a subsidiary of publicly traded Panasonic Corporation (“Panasonic”), agreed to pay a $137 million criminal penalty under a deferred prosecution agreement to resolve FCPA liability. According to the agreement, PAC caused parent Panasonic to falsify its books and records with respect to improper payments that PAC made to third-party consultants and sales agents, in violation of the FCPA’s accounting provisions. In addition to the criminal penalty, the agreement imposes a two-year independent compliance monitorship on PAC, to be followed by an additional year of self-reporting. Authorities noted that PAC received a 20 percent discount from the low end of the U.S. Sentencing Guidelines fine range for its cooperation and remediation, highlighting the fact that several senior executives who were involved in or aware of the misconduct had been separated from PAC or Panasonic. Panasonic separately agreed to pay approximately $143 million in disgorgement to the SEC.
United States v. Panasonic Avionics Corp., 18-cr-00118 (D.D.C.)