On March 26, 2018, the Securities and Exchange Commission (SEC) announced that Kinross Gold Corporation, a Canadian mining company with shares on the New York Stock Exchange, had settled claims of civil Foreign Corrupt Practices Act (FCPA) violations involving inadequate accounting controls over two West African subsidiaries. In the order, the SEC stated that despite conducting pre-acquisition due diligence and several post-acquisition audits that found widespread anti-corruption compliance and accounting deficiencies, Kinross took three years to implement controls after acquiring the subsidiaries, failed to remediate the issues discovered by its own due diligence, and failed to consistently apply its own internal accounting controls after implementing them.1 As part of the settlement…
