Today we begin with the background.Īccording to the SEC Press Release, “WPP implemented an aggressive business growth strategy that included acquiring majority interests in many localized advertising agencies in high-risk markets. In other words, there is much to parse from this enforcement action, and I do not know how many posts I will pen about it. It is also interesting from what is not in the record regarding self-disclosure, the Department of Justice (DOJ), the UK Serious Fraud Office (SFO) and the lack of a monitor. These compliance angles include tone at the top, culture, whistleblowers and internal reporting, internal investigations, mergers and acquisitions (M&A), missed red flags, conscious indifference and financial incentives. Not from the amount of the fine and penalty perspective but from a variety of other angles that are instructive from the compliance perspective. WPP agreed to pay $11 million+ in disgorgement and interest and penalty of $8 million for a total amount of just over $19 million.Īll I can say is that the WPP enforcement action is quite a doozy. The Securities and Exchange Commission (SEC) entered into a Cease and Desist Order (Order) last week with WPP plc, the world’s largest advertising group, for the paying bribes to Indian government officials and participating in other “illicit schemes” in China, Brazil and Peru. We now have our second Foreign Corrupt Practices Act (FCPA) corporate enforcement action in 2021.

Association of advertising agencies