Qualcomm's New Disclosure
The FCPA Blog | Tuesday, July 24, 2012 at 9:28AM 
San Diego-based Qualcomm Incorporated updated its FCPA disclosure last week. It first disclosed in January that a whistleblower complaint triggered an investigation.
Qualcomm provides wireless technology and services. Revenues last year were about $15 billion. It operates primarily in China, South Korea, Taiwan, Japan, and the United States.
In its quarterly report filed July 18, it said:
On September 8, 2010, the Company was notified by the SEC's Los Angeles Regional office of a formal order of private investigation. The Company understands that the investigation arose from a "whistleblower's" allegations made in December 2009 to the audit committee of the Company's Board of Directors and to the SEC. In 2010, the audit committee completed an internal review of the allegations with the assistance of independent counsel and independent forensic accountants. This internal review into the whistleblower's allegations and related accounting practices did not identify any errors in the Company's financial statements. On January 27, 2012, the Company learned that the U.S. Attorney's Office for the Southern District of California/DOJ (DOJ) had begun a preliminary investigation regarding the Company's compliance with the Foreign Corrupt Practices Act (FCPA). The Company believes that FCPA compliance has also become a focus of the SEC investigation. The audit committee has commenced an internal review into the Company's compliance with the FCPA with the assistance of independent counsel.
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