In the second article of this two-part series, John Davis concluded his analysis of the Securities Exchange Commission's (SEC) settlement with Deere & Company (d/b/a John Deere), analyzing the settlement's implications for post-acquisition integration and how John Deere remediated its compliance issues. The Department of Justice's (DOJ) M&A Safe Harbor policy combined with the SEC's settlement with Deere, "show that the FCPA enforcers believe that effective post-closing compliance and accounting controls integration are key elements of a corporate compliance program," said Davis, noting, "[w]hatever the realistic timeline, companies should make addressing the potentially higher compliance risk a priority as part of the overall business integration." Among other topics, Davis also highlighted the importance of management support for compliance training and communications, noting "[e]mployees need to see that managers are both 'talking the talk' and 'walking the walk' for compliance messaging to stick."