b'The information also alleges that Beam willfully failed to implement proper internal controls. For instance, Beam failed to conduct sufficient due diligence before it acquired Beam India in 2006. Further, Beam ignored the findings and recommendations of an accounting firm hired by Beam to review Beam Indias compliance policies in 2011, despite the fact that the accounting firm identified several red flagsnot be imposed on Beam India because of India[s] customs and ways of doing business. At the conclu-sion of the investigation, the Indian law firm issued a report that largely repeated the findings and recom-mendations of the global accounting firms previous review. And a U.S. law firm engaged by Beam to review the Indian law firms report identified several areas of necessary further investigationincluding undertaking a comprehensive review of past invoice payments to Beam Indias third-party promotersand made several recommendations for how Beam should improve compliance and internal accounting controls. But Beam ignored the U.S. law firms recommendations, failed to conduct a financial investigation of past invoices, and took no measures to improve its internal accounting controls with respect to third-party sponsors. Emails contained in the information indicate that Beam executives did not want anyone digging and finding past illegal payments that Beam cannot remediate or change and that they were only concerned with concluding the compliance review as expeditiously and with as little disruption as possible, particularly given Beams impending listing as a public company. The information alleges that, as a result of the bribes by Beam India, Beam maintained false books and records and falsified certifications, including Sarbanes-Oxley sub-certifications that falsely stated that APSA exec-utives had no knowledge of any fraud or suspected fraud. On October 23, 2020, the DOJ announced that it had entered into a DPA with Beam. Under the DPA, Beam agreed to pay a civil monetary penalty of $19.6 million, which reflects a 10% reduction from the bottom end of the applicable range under the Sentencing Guidelines. Beam also must fully cooperate in any existing or future 21'