SEC Charges 3M with Foreign Corrupt Practices Act Violations Relating to China Subsidiary

The Securities and Exchange Commission today announced that 3M Company agreed to pay more than $6.5 million to resolve charges that it violated the books and records and internal controls provisions of the Foreign Corrupt Practices Act (FCPA). The SEC’s order finds that employees of a 3M wholly owned subsidiary based in China arranged for Chinese government officials employed by state-owned health care facilities to attend overseas conferences, educational events, and health care facility visits, ostensibly as part of the Chinese subsidiary’s marketing and outreach efforts. However, the arrangements to attend the events were often a pretext to provide the Chinese government officials with overseas travel, including tourism activities, to induce them to purchase 3M products.