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 | Investigations Dataset

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

Investigations Dataset

 
Investigation into eLandia, Inc.'s/Latin Node's Activities in Central America · eLandia, Inc.

Information & Summary

Investigation into eLandia, Inc.'s/Latin Node's Activities in Central America

Related FCPA Matter:   Latin Node's Involvement in Honduras and Yemen in 2004 Information

Information & Summary

Investigation Name:    Investigation into eLandia, Inc.'s/Latin Node's Activities in Central America

Trend:    None

Type of investigation:    Internal, DOJ

Other Agencies Investigating/Assisting with DOJ Investigation:    Unknown

Whistleblower:    Unknown

Summary

Latin Node, Inc. ("Latinode"), which was headquartered in Miami, Florida, provided wholesale telecommunications services using internet protocol technology in a number of countries throughout the world. In June 2007, eLandia International, Inc. ("eLandia") acquired Latinode.

According to its SEC filings, and as a part of its acquisition and integration of Latinode, eLandia engaged in a review of Latinode’s internal controls and legal compliance procedures with its finance and accounting departments. Elandia identified certain past payments to consultants in Central America that were made in the absence of adequate records and controls for a U.S. public company. Elandia’s Management initiated an investigation to determine that no indirect payments by consultants used by Latinode were made in violation of the FCPA.

As disclosed in eLandia’s November 12, 2008 10-Q filing, on April 3, 2008, the DOJ issued a subpoena requesting certain information from eLandia in connection with the company’s investigation of Latinode’s FCPA matter.

According to its May 19, 2009 10-Q filing, eLandia had voluntarily and proactively reported the potential FCPA violations of Latinode to the SEC, DOJ and FBI and cooperated fully with these agencies regarding the matters.

As part of eLandia’s settlement negotiations with the DOJ, Latinnode entered into an agreement with the DOJ to resolve the FCPA investigation for the actions that occurred prior to acquisition by eLandia.

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