KT Corporation, South Korea’s largest telephone company, disclosed in a securities filing on April 29, 2020, that it was being investigated by the US Securities and Exchange Commission for possible violations of the US Foreign Corrupt Practices Act. The filing did not describe the substance of the SEC’s investigation other than to say it “related to” certain other matters described in the filing, including:
(1) A case involving former President of South Korea Geun-hye Park in which President Park was accused of having coerced KT Corporation into (a) donating money to two non-profit foundations, (b) hiring two individuals, and (c) awarding advertising contracts to a company in which a “confidante” of President Park, Soon-sil Choi, effectively owned 70%;
(2) A case involving a former member of the National Assembly who allegedly coerced KT Corporation into donating money to an organization for which the assemblyman previously served as president;
(3) An investigation into allegations that current and former KT Corporation employees used corporate funds to give gifts or make donations to South Korean politicians, in violation of Korean law; and
(4) An investigation into allegations that KT Corporation’s former CEO entered into contracts with certain former public officials in a “criminal breach of fiduciary duty.”
KT Corporation stated that it was cooperating with the SEC investigation.