FCPA Scorecard Blog
Mondelez International Discloses Wells Notice Regarding India Operations
Snack food company Mondelez International announced in its 10-K on Friday that it had received a Wells notice from the SEC regarding potential violations of the FCPA at an Indian factory. The Wells notice marks the latest development in a long-running FCPA investigation dating back to 2011, when Mondelez first received a subpoena from the SEC. The Indian operations were integrated into Mondelez following its 2010 acquisition of Cadbury; the SEC's allegations relate to interactions "with Indian governmental agencies and officials to obtain approvals related to the operation of that facility." The Wells notice indicated an intent by the SEC staff to recommend the filing of an enforcement action for violations of the FCPA's books and records and internal controls provisions. Mondelez has noted that it is cooperating with both the U.S. and Indian governments in various investigations.