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 | Investigations Dataset

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

Investigations Dataset

 
Investigation into Quad/Graphics' Activities in Peru, China, and Cuba · Quad/Graphics, Inc.

Information & Summary

Investigation into Quad/Graphics' Activities in Peru, China, and Cuba

Related FCPA Matter:   Quad/Graphics, Inc.'s Involvement in Peru, China, and Cuba Information

Information & Summary

Investigation Name:    Investigation into Quad/Graphics' Activities in Peru, China, and Cuba

Trend:    None

Type of investigation:    Internal, SEC, DOJ

Other Agencies Investigating/Assisting with SEC/DOJ Investigation:   

  • U.S. Office of Foreign Asset Control
  • Peruvian National Institute for the Defense of Competition and Intellectual Property

Whistleblower:    Unknown

Summary

Quad/Graphics, Inc. ("Quad") was a Wisconsin-based marketing solutions and printing services company with operations in 10 countries. Quad’s common stock was registered with the SEC and traded on the New York Stock Exchange.

In its May 4, 2016 10-Q filing, Quad disclosed that its financial internal controls had identified certain Foreign Corrupt Practices Act ("FCPA") issues related to its Peru operations. Under the oversight of its Audit Committee and Board of Directors, Quad proactively initiated an investigation into this matter with the assistance of external legal counsel and external forensic accountants. The company made certain enhancements to its compliance program in connection with the investigation.

In April 2016, Quad self-reported the FCPA issues to the SEC and the DOJ. The company disclosed that it is fully cooperating with the SEC and the DOJ.

In its annual report filed on February 22, 2017, Quad disclosed that its internal investigation had turned up possible misconduct in China as well.

In its November 1, 2017 10-Q filing, the company disclosed that its investigation uncovered certain relevant transactions involving Cuba. Quad also disclosed that it had told the Office of Foreign Assets Control, the SEC, and the DOJ about the transactions and that it was cooperating with the agencies.

On September 19, 2019, the DOJ informed Quad in a declination letter pursuant to the agency's FCPA Corporate Enforcement Policy that it did not intend to pursue an enforcement action against the company. The DOJ cited the company's self-reporting, cooperation, and remediation.

On September 26, 2019, the SEC filed an enforcement action against Quad/Graphics.

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