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 | Investigations Dataset

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

Investigations Dataset

 
Investigation into Microsoft's Activities in Multiple Countries · Microsoft Corporation

Information & Summary

Investigation into Microsoft's Activities in Multiple Countries

Related FCPA Matter:   Microsoft Corporation's Involvement in Multiple Countries Information

Information & Summary

Investigation Name:    Investigation into Microsoft's Activities in Multiple Countries

Trend:    None

Type of investigation:    Internal, SEC, DOJ

Other Agencies Investigating/Assisting with SEC/DOJ Investigation:   

  • Unspecified U.S. Authorities
  • Hungarian Law Enforcement Agency

Whistleblower:    Unknown

Summary

Microsoft Corporation (Microsoft), an American company headquarted in Washington, developed, licensed, and supported a wide range of software and services, among other things. Microsoft’s stock was registered with the SEC and traded on the NASDAQ.

On March 19, 2013, the Wall Street Journal (WSJ) reported that "[f]ederal regulators are investigating Microsoft Corp.'s relationship with business partners that allegedly bribed foreign government officials in return for software contracts, according to people familiar with the matter. Lawyers from the U.S. Justice Department and the Securities and Exchange Commission are examining kickback allegations made by a former Microsoft representative in China, as well as the company's relationship with certain resellers and consultants in Romania and Italy, these people said."

That same day, Microsoft released a blog posting that referenced the WSJ article and stated that "[t]he matters raised in the [article] are important, and it is appropriate that both Microsoft and the government review them." Microsoft did not confirm any of the other details disclosed in the WSJ article.

Microsoft did not disclose the investigation in its public SEC filings until July 28, 2016, when it confirmed that it has "been cooperating with authorities in the US in connection with reports concerning our compliance with the Foreign Corrupt Practices Act in various countries."

On July 22, 2019, the SEC and DOJ initiated enforcement actions against Microsoft and its Hungarian subsidiary, respectively, for violations of the books and records and internal controls provisions of the FCPA.

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