ADM reveals three-year foreign-corruption compliance internal probe

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For three years global agriculture giant Archer Daniels Midland Company has been conducting an internal investigation to determine whether it violated the Foreign Corrupt Practice Act or other U.S. laws in its business dealings, the company reported last week in a filing with the Securities and Exchange Commission. "Since August 2008, the Company has been conducting an internal review of its policies, procedures and internal controls pertaining to the adequacy of its anti-corruption compliance program and of certain transactions conducted by the Company and its affiliates and joint ventures, primarily relating to grain and feed exports, that may have violated company policies, the U.S. Foreign Corrupt Practices Act, and other U.S. and foreign laws," ADM stated in its form 10-K filing. The document added that ADM initially disclosed its review to the U.S. Justice Department, the SEC, and certain foreign regulators in March 2009 and has subsequently provided periodic updates to the agencies. It also stated that the company has "engaged outside counsel and other advisors to assist in the review of these matters and has implemented, and is continuing to implement, appropriate remedial measures." The filing noted that ADM could face civil or criminal fines and could be ordered to disgorge profits, but said that such penalties are not expected to have a "material impact" on the company's business or financial condition. It is not unusual for an FCPA internal review to last for several years, in part because the event that sparks such an investigation can lead to additional discoveries. Beauty company Avon Products Inc has been conducting an internal probe into possible FCPA violations since 2008 and has spent more than $150 million on the effort.