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 | Investigations Dataset

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

Investigations Dataset

 
Investigation into SQM's Activities in Unspecified Countries · Sociedad Quimica y Minera de Chile S.A.

Information & Summary

Investigation into SQM's Activities in Unspecified Countries

Related FCPA Matter:   Sociedad Quimica y Minera de Chile's Involvement in Chile Information

Information & Summary

Investigation Name:    Investigation into SQM's Activities in Unspecified Countries

Trend:    None

Type of investigation:    Internal, SEC, DOJ

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

Whistleblower:    Unknown

Summary

Sociedad Quimica y Minera de Chile ("SQM") was a Chilean chemicals and mining company. SQM's stocks were registered with the SEC and traded on the New York Stock Exchange as American Depositary Receipts.

As disclosed in its December 29, 2016 6-K filing, SQM's Board of Directors formed an Ad-Hoc Committee (the Committee) starting April 24, 2015.

The Committee engaged the law firms Shearman & Sterling and Vial / Serrano, and the forensic services provided by the US company FTI Consulting, Inc. to conduct an investigation and provide analysis of the possible liabilities to which SQM may be exposed under the standards of the FCPA applicable to the company. Specifically, the investigation was focused on conducting an analysis of: (a) whether SQM had made any undue payment defined as a corrupt practice for FCPA purposes; and (b) whether SQM had not complied with the accounting regulations in accordance with that established in the FCPA.

On December 15, 2015, the Committee reported to the Board of Directors the results, conclusions and recommendations resulting from the internal investigation, and reported the results, conclusions and recommendations to the Chilean Authorities and on January 7, 2016, also reported to the DOJ and the SEC.

Both the DOJ and SEC initiated investigations to determine the existence of possible noncompliance with the FCPA and /or internal controls standards. On January 13, 2017, SQM settled FCPA-related claims with both the SEC and the DOJ.

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