One year after an SEC investigation revealed executives had not disclosed their personal use of a corporate jet Stanley Black & Decker (SWK), a tool maker, is being probed over more serious matters. In its latest annual report, Stanley indicates it may have violated a federal law prohibiting the bribing of foreign officials in return for business, stating the firm has:

“...identified certain transactions relating to its international operations that may raise compliance questions under the U.S. Foreign Corrupt Practices Act (“FCPA”)...”

Stanley says it told the SEC and DOJ about the transactions and is “cooperating with both agencies in their investigations.”

The revelation was included in the company’s latest annual report but Stanley does not date the investigation.

In December of 2022, DuDil confirmed an undisclosed SEC investigation of Stanley unrelated to the executive jet issue or recent EPS restatements. The undisclosed investigation has been underway since at least February 23, 2022. In denying our FOIA appeal for records related to the undisclosed investigation, the SEC confirmed the investigation for which we sought records is “active and ongoing” and:

“We have confirmed with Division of Enforcement staff that the documents you seek…could be reasonably expected to cause harm to the ongoing and active enforcement proceedings because, among other things, individuals and entities of interest in the underlying investigation could fabricate evidence, influence witness testimony and/or destroy or alter certain documents.”

If the undisclosed investigation DuDil uncovered is the same as the bribery probe, Stanley waited a year to disclose the matter to investors.