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Email In a settlement highlighting the need for public companies to implement – and adhere to – effective internal controls, United Airlines “United” recently paid a $2.4 million civil penalty to the Securities and Exchange Commission “SEC” for failing to follow its own compliance policies and procedures designed to prevent corrupt payments. https://www.cadwalader.com/resources/clients-friends-memos/united-airlines-settles-with-sec-for-side-stepping-its-own-anti-corruption-controls--management-override-for-a-ride-over-to-south-carolina