A company named one of the world’s most ethical in March 2018 for the tenth consecutive year settled FCPA charges with the SEC for $9 million in April. The SEC issued a cease-and-desist order against Dun & Bradstreet Corporation relating to improper payments made by subsidiaries to Chinese government officials after a six-year investigation. The DOJ simultaneously issued a declination and stated that its decision is “consistent with the FCPA Corporate Enforcement Policy” citing Dun & Bradstreet’s self-disclosure, cooperation, remediation and assistance in identifying individuals responsible for misconduct. Dun & Bradstreet, however, only self-disclosed its China problem after a revelation on a Chinese television program prompted a local police raid on its subsidiary there. The Anti-Corruption Report addresses the takeaways from the resolution. See our three-part series on the DOJ’s FCPA Corporate Enforcement Policy: “What’s New and What’s Not” (Jan. 10, 2018); “How Important Is the Presumption of Declination?” (Jan. 24, 2018); and “Cooperation and Compliance Expectations” (Feb. 7, 2018).