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Teradata FCPA investigation ends with double declination

Teradata Corporation said in an SEC filing Friday that the FCPA investigation into gifts and travel expenses at a subsidiary in Turkey has ended and the company won't face an enforcement action.

The SEC advised Teradata in January that its investigation was closed. And on February 20, the company received a declination from the DOJ.

Ohio-based Teradata develops and sells enterprise software for database management. It has about 10,000 employees in 43 countries.

The company said in August last year that it discovered "questionable expenditures for travel, gifts and other expenses" at a subsidiary doing business in Turkey.

Teradata said it had contacted the SEC and DOJ in late February 2017, "to alert them to the relevant events and the . . . internal investigation."

The disclosure last year said Teradata had taken "remedial actions and terminations," and that individuals involved in the conduct were no longer working for the company.

*     *     *

The full FCPA disclosure from Teradata Corporation's February 23, 2018 Form 10-K said:

As first disclosed in the Company’s Form 10-Q for the second quarter of 2017, through internal processes, the Company discovered certain questionable expenditures for travel, gifts and other expenses at one of its international subsidiaries doing business in a single foreign country, Turkey. Teradata promptly initiated an internal investigation into the matter, with the assistance of outside counsel and forensic accountants, to determine whether the expenditures may have violated the U.S. Foreign Corrupt Practices Act (“FCPA”) or other potentially applicable anti-corruption laws. In February 2017, the Company voluntarily contacted the SEC and the U.S. Department of Justice (“DOJ”) to alert them to the relevant events and the Company's internal investigation. Teradata has fully cooperated with the government regarding the status of the Company's internal investigation and findings, including remedial actions and terminations.

On January 16, 2018, the SEC advised that its staff will not recommend any enforcement action by the SEC against Teradata and that its investigation into this matter is closed. On February 20, 2018, the DOJ also advised the Company that it will not take any enforcement action and that its investigation into this matter is closed.


Richard L. Cassin is the publisher and editor of the FCPA Blog.