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 | Investigations Dataset

Stanford Foreign Corrupt Practices Act Clearinghouse a Collaboration with Sullivan & Cromwell LLP

Investigations Dataset

 
Investigation into Laureate Education's Activities in Turkey in 2014 · Laureate Education Inc.

Information & Summary

Investigation into Laureate Education's Activities in Turkey in 2014

Related FCPA Matter:   Laureate Education's Involvement in Turkey in 2014 Information

Information & Summary

Investigation Name:    Investigation into Laureate Education's Activities in Turkey in 2014

Trend:    None

Type of investigation:    Internal, SEC, DOJ

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

Whistleblower:    Unknown

Summary

Laureate Education, Inc. (Laureate) is a publicly traded.corporation based in the United States with campuses in Mexico and Peru. It offers undergraduate, graduate and specialized degree programs. Its stock trades on the NASDAQ.

According to company filings, Laureate recorded an expense of $18 million in the 4th quarter of 2014 for a donation one of its network institutions had made to a charity in Turkey. It was later discovered that the donation may have been improperly distributed by the charity to an unnamed third party at the direction of a former senior executive at the network institution without the knowledge or approval of Laureate.

In June 2016, the audit committee of Laureate's board of directors hired outside counsel to initiate an internal investigation into the matter. In September 2016, the company voluntarily disclosed its investigation to the DOJ and SEC, which began their own investigations into the matter. Laureate reported that it was fully cooperating with the agencies. Additionally, the company said that it had taken certain remedial steps in connection with the matter, including enhancement of its internal controls and compliance policies as well as the termination of the senior executive at the network institution in Turkey.

In an 8-K filed on November 29, 2018, Laureate disclosed that it had received letters from both the SEC and DOJ informing the company that the agencies' respective investigations had been concluded with no further action. The DOJ noted the company's voluntary disclosure, full cooperation, and remediation.

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