O’Melveny’s Cheng Quoted in FCPA Report on Johnson Controls Settlement

August 02, 2016

O’Melveny partner Ron Cheng was quoted in the July 27, 2016, FCPA Report article “Could Johnson Controls Have Prevented the Flagrant Circumvention of Its Revamped Compliance Program?” The piece details Johnson Controls Inc.’s agreement to pay US$14 million to resolve SEC charges that employees of its subsidiary China Marine undermined the company’s revamped internal controls systems to make payments to sham vendors. 

“The SEC order makes clear that China Marine structured the new vendor-based fraud to evade the agent-oriented controls created under the prior settlement,” Cheng said in the article, adding, “This kind of scheme creates challenges for a company, particularly with numerous vendors and transactions.”

With more than 10 years of experience dealing with criminal enforcement matters in China and Asia, Cheng handles anti-corruption and data privacy matters and is co-located in O’Melveny’s Hong Kong and Los Angeles offices.