An issuer parent is strictly liable for accounting violations of its subsidiaries, as the subsidiaries’ books are consolidated into the parent’s financials, rendering them inaccurate.
For anti-bribery violations, it is usually acknowledged that the government must show that the parent ordered, authorized, assisted or conspired with the subsidiary to violate the anti-bribery provisions, but a number of recent cases show that the SEC will charge a foreign issuer parent without making such a showing on the theory that the subsidiary is acting as the agent of the foreign issuer parent.
Liability under the anti-bribery provisions carries much more significant reputational risks.