JUNIPER NETWORKS

INDUSTRY

Technology / Software / Electronics

CORPORATE HEADQUARTERS

Sunnyvale, California, United States

SUMMARY OF ALLEGATIONS

Nationality of Foreign Officials: China, Russian Federation

Summary of Allegations:

In it's SEC Form 10-Q filed on 8 August 2013 Juniper Networks disclosed that "the U.S. Securities and Exchange Commission ("SEC") and the U.S. Department of Justice ("DOJ") are conducting investigations into possible violations by the Company of the U.S. Foreign Corrupt Practices Act ("FCPA"). The Company is cooperating with these agencies regarding these matters. The Company is unable to predict the duration, scope or outcome of these investigations."

Juniper never publicly disclosed where the possible FCPA violations may have occurred who was alleged to have been involved.

29 August 2019: The SEC issued a consensual cease-and-desist order that described the facts surrounding Juniper's FCPA violations: 

Between 2008 and 2013, employees of Juniper’s wholly-owned Russian subsidiary JNN Development Corp. (“JNN”) engaged in a scheme with various third-party channel partners to increase the incremental discount on sales made to customers through the channel partners without passing the discounts on to the customers. Rather, the channel partners siphoned the additional discounts into an off-book “common fund” that JNN employees would use to pay for customer leisure trips, including trips for various government officials. The trips had no legitimate business purpose and were aimed at improperly influencing the recipients to use their positions to help Juniper win additional business advantages.

Between 2009 to 2013, two of Juniper’s wholly-owned Chinese subsidiaries – Juniper Networks R&D Ltd and Juniper Networks Shanghai Ltd. – provided excessive travel and entertainment-related benefits to various customers, some of whom were foreign officials. Such expenses violated Juniper policy and were approved based on falsified trip agendas that understated the true value and purpose of the hospitality expenditures.


Approximate Alleged Payments to Foreign Officials: at least $US 4 million; trips and entertainment-related expenses that were often excessive and against Juniper policy.

Business Advantage Allegedly Obtained: Business advantage.

ENFORCEMENT RESULTS

Agencies: United States: Department of Justice
Results: Declination
Year Resolved: 2018
Compliance Monitor:
Ongoing: No
Details:

2013 - The DOJ commenced an investigation into whether Juniper violated the FCPA. No additional details are available.

12 February 2018 - Juniper Networks confirmed that the DOJ concluded its investigation of the company's alleged FCPA violation and will not take action.



Agencies: United States: Securities and Exchange Commission
Results: Administrative Order, Cease-and-Desist Order, Civil Penalty, Disgorgement
Year Resolved: 2019
Compliance Monitor: No
Ongoing: No
Details:

2013: The SEC commenced an investigation into whether Juniper violated the FCPA. No additional details are available.

12 February 2018: The SEC's investigation of Juniper's alleged FCPA violation is ongoing.

29 August 2019: the U.S. Securities and Exchange Commission resolved FCPA claims against U.S.-based technology company Juniper Networks (“Juniper”) stemming from violations of the internal accounting controls and recordkeeping provisions of the FCPA related to the improper sales and travel practices of Juniper’s Chinese and Russian subsidiaries.

The SEC issued a consensual cease-and-desist order against Juniper requiring the company to pay a total of approximately US$ 11.7 million (US$ 4 million in disgorgement, US$ 1.2 million in prejudgment interest, and a civil penalty of US$ 6.5 million).



ENTITIES/INDIVIDUALS INVOLVED

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