Avon Products, Inc. (Avon) and its Chinese subsidiary, Avon Products (China) Co., Ltd. (Avon China), resolved an FCPA inquiry that had been ongoing since 2008. Avon entered into a three-year-and-seven-day deferred prosecution agreement, pursuant to which it agreed to engage an outside monitor for at least 18 months, and also agreed to pay a criminal penalty of $67.65 million, which will be satisfied by Avon China’s payment of its penalty in the same amount. See Deferred Prosecution Agreementbetween U.S. Dep’t of Justice and Avon Products, Inc., re:  United States v. Avon Products, Inc. (Dec. 15, 2014).  Avon also settled a related SEC enforcement action and agreed to pay more than $67.36 million in disgorgement and prejudgment interest.  See ComplaintSEC v. Avon Products, Inc., No. 14-cv-09956 (S.D.N.Y. Dec. 17, 2014), ECF No. 1.  Avon China pleaded guilty to one count of conspiracy to violate the books and records provision of the FCPA and to pay a criminal penalty of $67.65 million. See Plea Agreementbetween U.S. Dep’t of Justice and Avon Products (China) Co. Ltd., re:  United States v. Avon Products (China) Co. (Dec. 15, 2014).  Together, Avon and Avon China will pay $135 million to settle these matters.  As the agreement states, Avon entities acknowledged that between at least 2004 through the third quarter of 2008, Avon China gave cash and other things of value, including meals, gifts, travel, and entertainment, to Chinese government officials, including officials responsible for awarding a test license, and subsequently a direct sales business license, that would allow Avon to conduct door-to-door sales in China.  The agreement also states that Avon China failed to record these expenses accurately and completely in its books and records, which were consolidated into Avon’s books and records.