Juniper Networks Inc. (Juniper), 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 disclosed in its SEC filings that both the SEC and the DOJ were conducting investigations into possible violations of the FCPA. Juniper’s Audit Committee, with the assistance of independent advisors, began an internal investigation and made recommendations for remedial measures, which the company implemented. Juniper disclosed that it was cooperating with the agencies’ investigations.
In an 8-K filed on February 9, 2018, Juniper disclosed that the DOJ had completed its investigation and, citing Juniper's cooperation, decided to take no further action against the company. Subsequent filings indicate that the DOJ had sent the letter closing its investigation in the fourth quarter of 2017.
In its second quarter 10-Q filed on August 8, 2018, Juniper disclosed that the SEC's investigation was likely to result in an enforcement action. Though the precise timing of any SEC action is unknown, Juniper disclosed in its subsequent 10-Q filed on November 7, 2018, that it had set aside $12 million in connection with the SEC's investigation.
On August 29, 2019, the SEC initiated a settled administrative proceeding against Juniper.
