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Oct. 23, 2024

John Deere Settlement: M&A Integration, Commercial Bribery and Compliance Remediation

  • Megan Zwiebel
    Anti-Corruption Report
The recent settlement between Deere & Company, which does business as John Deere (Deere), and the SEC shows that failing to integrate a newly acquired subsidiary can create significant risk. In this second article of a two-part series unpacking the Deere settlement, we discuss the lessons it offers for post-acquisition integration, the SEC’s focus on Deere’s commercial bribery and how the company remediated its compliance issues. The first installment examined the internal controls failures that allowed Deere’s subsidiary in Thailand to entertain Thai officials at massage parlors and send them on European vacations. See “Safe Harbor Policy Seeks to Encourage Self-Reporting of Issues in M&A Transactions” (Oct. 11, 2023).

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