Deere & Company (Deere), which does business under the name John Deere, recently entered into a cease-and-desist order with the SEC to settle allegations that its wholly owned subsidiary in Thailand engaged in some bad behavior after being acquired by Deere. In a slow year for FCPA enforcement, the settlement offers insight into the SEC’s increasingly critical eye for companies’ compliance programs. This first article in a two-part series unpacks the lessons from the Deere settlement and focuses on the internal controls failures that allowed Deere’s subsidiary to lavish Thai officials with travel and entertainment to win tenders. Part two will highlight Deere’s failure to integrate its new subsidiary after its acquisition, how the SEC used the FCPA’s books-and-records provisions to sweep in allegations of commercial bribery, and the company’s remediation efforts. See “Travel and Side Trips Lead 3M to a $6.5‑Million SEC Resolution” (Oct. 11, 2023).