Yesterday the Securities and Exchange Commission (SEC) resolved a Foreign Corrupt Practices Act (FCPA) enforcement action involving Kinross Gold Corporation (Kinross). It was a civil matter and there was no evidence of bribery presented in the SEC Order but rather a violation of the FCPA’s accounting provisions; both in terms of the books and records and internal controls provisions. Although Kinross is headquartered in Canada, it was subject to SEC jurisdiction, pursuant to Section 12(b) of the Securities Exchange Act of 1934 and through its listing on the New York Stock Exchange. For its violations of the FCPA, Kinross agreed to pay a civil fine of $950,000.
The enforcement action presents some excellent lessons for every Chief Compliance Officer (CCO), compliance…
