Foreign Corrupt Practices Act: Investigations Dataset

Investigation Name: Investigation into IBM's Activities in Poland

Trend: None

Type of investigation: SEC, DOJ

Other Agencies Investigating/Assisting with SEC/DOJ Investigation:

Polish Anti-Corruption Bureau

Whistleblower: Unknown

Summary

International Business Machines Corporation ("IBM") is a New York corporation based in Armonk, New York. IBM develops and manufactures information technology products and services worldwide. IBM's common stock is traded on the NYSE.

According to its October 25, 2016 10-Q filing, in early 2012, IBM notified the SEC of an investigation by the Polish Central Anti-Corruption Bureau involving allegations of illegal activity by a former IBM Poland employee in connection with sales to the Polish government. IBM continues to cooperate with the SEC and Polish authorities in this matter. IBM was required to make reports to the SEC on certain matters relating to compliance with the FCPA during this time period because of a 2011 settlement with the SEC.

In April 2013, IBM learned that the U.S. Department of Justice (DOJ) was also investigating allegations related to the Poland matter, as well as allegations relating to transactions in Argentina, Bangladesh and Ukraine. The DOJ was also seeking information regarding IBM’s global FCPA compliance program and its public sector business.

In June 2017, both the DOJ and the SEC informed IBM that they had closed their respective investigations and would not be pursuing any enforcement actions.

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| Investigations Dataset

Investigations Dataset

Information & Summary

Investigation into IBM's Activities in Poland

Information & Summary

Protected Content