In a Nov. 1 quarterly filing, Leidos cryptically said “through its internal processes, the company discovered in late 2021 activities by its employees, third-party representatives and subcontractors, raising concerns related to a portion of our business that conducts international operations.”
Leidos added that it is conducting an internal investigation that is being “overseen by an independent committee of the board of directors, with the assistance of external legal counsel,” to determine whether the identified conduct may have violated the company’s Code of Conduct, the FCPA, and other applicable laws.
“The company has voluntarily self-reported this investigation to the Department of Justice and the Securities and Exchange Commission and is cooperating with both agencies,” Leidos said in regulatory filing.
Leidos further disclosed that it received a federal grand jury subpoena in September 2022 related to the criminal investigation by the U.S. Attorney’s Office for the Southern District of California, in conjunction with the DoJ’s Fraud Division.
“The subpoena requests documents relating to the conduct that is the subject of the company’s internal investigation,” Leidos said. “The company is in the process of responding to the subpoena.”
Antitrust Investigation
The subpoena that Leidos received in September 2022 was the second one received in a span of a month. In August 2022, the company received a federal grand jury subpoena in connection with a criminal investigation being conducted by the DoJ’s Antitrust Division.
“The subpoena requests that the company produce a broad range of documents related to three U.S. government procurements associated with the company’s Intelligence Group in 2021 and 2022,” the company said.
“We intend to fully cooperate with the investigation, and we are conducting our own internal investigation with the assistance of outside counsel,” Leidos added. “It is not possible at this time to determine whether we will incur, or to reasonably estimate the amount of, any fines, penalties, or further liabilities in connection with the investigation pursuant to which the subpoena was issued.” 
Jaclyn Jaeger is a contributing editor at Compliance Chief 360° and a freelance business writer based in Manchester, New Hampshire.