b'agency, but it also suggests that the DOJ was diverted to state-owned healthcare providers and comfortable with Airbus remediation and cooperation.employees of state-owned retailers in an attempt to The DPAs in France and the UK involved misconduct,promote the sale of the European cosmetic compa-arising in China, Colombia, Nepal, Russia, Saudi Arabia,nys products. These illegal payments involved travel, South Korea, Taiwan, the UAE, Ghana, Indonesia,luxury goods, cash, and gift cards. Further, Cardinal Malaysia, Sri Lanka, and Taiwan. Healths inadequate internal accounting controls enabled the marketing employees to easily disguise the improper payments by laundering the funds through In the Matter of Cardinal Health, Inc., complicit third party vendors and mislabeling the No. 3-19718payments in Cardinal Chinas books and records. The SEC found that Cardinal Health failed to adequately On February 28, 2020, the SEC announced that it hadrespond to numerous red flags. Cardinal Health entered into a settlement agreement with Cardinalrecognized the FCPA-compliance risks early on; Health, an Ohio-based pharmaceutical company thatshortly after the Company acquired Cardinal China in is publicly traded on the New York Stock Exchange, for2010, it instructed Cardinal China to wind down the violating the internal accounting and books and recordsmarketing accounts because of the possibility that they provisions of the FCPA through the misconduct ofcould be used to channel illegal payments to Chinese Cardinal Healths Chinese subsidiary (Cardinal China).government officials. But Cardinal China failed to wind After Cardinal Health purchased a Chinese phar- down the marketing accounts for many suppliers, maceutical distribution company in 2010, Cardinalincluding those of the European cosmetic company China became exclusive distributor in the Chineseand Cardinal Health, despite being on notice, failed to market for a third-party European cosmetic company.ensure that Cardinal China did so, or to even assess Cardinal China also administered the European compa- whether Cardinal China had implemented improved nys marketing accounts and employed thousandscontrols to reduce the compliance risks stemming of employees on the European companys behalf,from the European cosmetic companys marketing including approximately 100 sales and marketingaccounts. Also in 2012, Cardinal Health and Cardinal employees that promoted the European companysChina failed to adequately investigate a Cardinal China products to state-owned entities. The European compa-nys sales and marketing efforts benefitted Cardinal China, as Cardinal China received a distribution marginCardinal China regularly made payments on the sales of the European companys products. The SEC found that Cardinal China was unjustly enrichedthat were diverted to state-owned by $5.4 million between 2013 and 2016 due to profitshealthcare providers and employees it earned because of its relationship with the European cosmetic company.of state-owned retailers in an attempt The SEC found that Cardinal China failed to implementto promote the sale of the European sufficient internal accounting controls over the salescosmetic companys products. These illegal and marketing employees that it employed on behalf of the European cosmetic company. Between 2013 andpayments involved travel, luxury goods, 2016, Cardinal China authorized and paid over $250cash, and gift cards.million from the marketing accounts. In that period, Cardinal China regularly made payments that were 13'