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 | Investigations Dataset

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

Investigations Dataset

 
Investigation into BabyCare Ltd's Activities in China · USANA Health Sciences, Inc.

Information & Summary

Investigation into BabyCare Ltd's Activities in China

Related FCPA Matter:   USANA Health Sciences' Involvement in China Information

Information & Summary

Investigation Name:    Investigation into BabyCare Ltd's Activities in China

Trend:    None

Type of investigation:    Internal, SEC, DOJ

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

Whistleblower:    Unknown

Summary

USANA Health Sciences, Inc. (USANA) is a publicly held direct-selling nutrition, personal health and wellness company. Incorporated and headquartered in Utah, its common stock is traded on the New York Stock Exchange.

On February 7, 2017, USANA announced that it was conducting an internal investigation through outside counsel of its China operations, BabyCare Ltd, for possible FCPA issues. The investigation focused on certain conduct and policies at the subsidiary, including BabyCare’s expense reimbursement policies.

USANA voluntarily disclosed the investigation to the DOJ and SEC and have disclosed that the company continues to cooperate with both agencies as its investigation progresses. Though it was not specifically confirmed that the DOJ and SEC opened independent investigations into the company, in USANA's February 5, 2019 8-K, the company stated that its internal investigation was substantially complete but that it continued to cooperate with the agencies, which seems to imply that the DOJ and SEC have started their own investigations into the company.

In its 8-K filed on June 29, 2020, USANA disclosed that it had been informed by the SEC on June 24 and by the DOJ on June 26 that both agencies had concluded their investigations and did not intend to pursue further action. Both agencies noted USANA's cooperation, and the SEC further noted the company's voluntary self-disclosure and remediation.

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