Advertising Giant WPP’s Aggressive Growth Strategy Leads to SEC Settlement

WPP plc (WPP), the world’s largest advertising group, dual-headquartered in London and New York City, recently entered into a $19‑million settlement with the SEC. The SEC’s cease-and-desist order – in which WPP neither admitted nor denied wrongdoing – alleges violations of the anti-bribery, books and records, and internal accounting controls provisions of the FCPA by WPP and its majority-owned subsidiaries in India, China, Peru and Brazil. The case highlights the importance of incorporating due diligence into an aggressive growth strategy and not ignoring red flags at subsidiaries post-acquisition. See “Evolving Global Anti-Corruption Efforts: U.S., China and India” (Feb. 17, 2021).

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