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Investigations Dataset

 

Investigation Name:    Investigation into Embraer's Activities in Unspecified Countries

Trend:    None

Type of investigation:    Internal, SEC, DOJ

Other Agencies Investigating/Assisting with SEC/DOJ Investigation:    Unknown

Whistleblower:    Unknown

Summary

Embraer S.A., a company incorporated and headquartered in Brazil, was a large manufacturer of mid-size commercial and executive jets and supplier of defense aircraft to the Brazilian Air Force and other countries throughout the world. Embraer's shares were registered with the SEC and traded on the New York Stock Exchange.

As disclosed in its November 3, 2011 6-K filing, Embraer received a subpoena from the SEC in September 2010, and associated inquiries from the DOJ regarding possible non-compliance with the FCPA, in relation to certain aircraft sales outside of Brazil. In response to the inquiries of the SEC and DOJ, Embraer retained outside counsel to conduct an internal investigation into aircraft sales in three countries. In light of additional discovered information, Embraer voluntarily expanded the scope of its internal investigation to include sales in other countries, reported on this expansion to the SEC and the DOJ and otherwise cooperated with both agencies’ investigations.

In October 2016, Embraer finalized definitive agreements with both the SEC and DOJ to settle allegations of criminal and civil violations of the FCPA.

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