The United States Department of Justice has closed its investigation of Image Sensing Systems, Inc. related to potential violations of the Foreign Corrupt Practices Act. Image Sensing Systems learned in 2013 that two employees of its Polish subsidiary had been charged with violations of Polish law. The company’s Audit Committee engaged Greene Espel and local Polish counsel to conduct a thorough investigation, made voluntary disclosures to both the Department of Justice and the Securities and Exchange Commission, and worked with Greene Espel to enhance its compliance program. The SEC previously notified Image Sensing Systems that it had closed its investigation without recommending enforcement action. Greene Espel attorneys Peggy Kubicz Hall
, David Wallace-Jackson
, and Karl Procaccini
led the investigation and represented Image Sensing Systems before the DOJ and SEC. Greene Espel’s Compliance and Anti-Corruption
team regularly conducts internal investigations, performs due diligence, and provides advice on creating and enhancing compliance programs.