Three Years Of Investigations
Probes Reporter continued that it has been following both disclosed and undisclosed SEC investigations against Avon since October 2012. In letters dated December 17, 2014, and August 18, 2015, the SEC has “confirmed this company’s involvement in on-going enforcement proceedings.”
‘No New’ Activity
The report further noted that Avon “made no new disclosures of SEC investigative activity” since the conclusion of an investigation in December 2014. In addition, the investigation confirmed on August 18, 2015, “appears unrelated” to the previous disclosure.
$68 million was paid to settle the DOJ’s criminal investigation and $67 million settled the SEC’s civil investigation. As part of the settlement, Avon was also required to retain an independent monitor to review its FCPA compliance program for a period of 18 months, followed by an additional 18 months of