Juniper Networks Inc., headquartered in Sunnyvale, California, designed, manufactured, and sold networking equipment products and services, including routers, switches, and security firewalls, to telecommunication network service providers. Juniper’s common stock was registered with the SEC and traded on the New York Stock Exchange. Juniper operated in various countries through subsidiaries and third party intermediaries known as "channel partners." Among Juniper's subsidiaries were JNN Development Corp. (“JNN”), a wholly-owned subsidiary headquartered in Delaware with a representative office in Moscow, Russia, Juniper Networks R&D Ltd., a wholly-owned subsidiary based in Hong Kong, and Juniper Networks Shanghai Ltd., a wholly-owned subsidiary based in China.
According to the documents in this case, from 2008 through 2013, certain sales employees of Juniper's Russia subsidiary secretly agreed with third-party distributors to fund leisure trips for customers, including government officials through the use of off-book accounts. Even after a member of Juniper's senior management learned of the misconduct in Russia, Juniper's remedial efforts were ineffective in stopping the misconduct. Additionally, at the same time from 2009 to 2013, certain sales employees of Juniper's Chinese subsidiaries falsified trip and meeting agendas for customer events to understate the true amount of entertainment involved in the trips.
In a settled administrative proceeding initiated on August 29, 2019, the SEC ordered Juniper to cease and desist violations of the books and records and internal controls provisions of the FCPA. Under the terms of the settlement, Juniper agreed to pay disgorgement of $4,000,000 plus prejudgment interest of $1,245,018, and a civil penalty of $6,500,000, for a total payment of $11,745,018. The SEC noted Juniper's cooperation and remediation in its determination not to impose a civil fine in excess of $6.5 million.
