Adjudicated GB LSE

Tesco plc: £250M Premature Commercial Supplier Income Pull-Forward

Early recognition of commercial income from supplier promotions and rebates that had not yet been earned under contract terms.

CASE PROFILE & BENCHMARKS

Target Issuer: Tesco plc (GB).
Fraud Period: January 1, 2017 to December 31, 2019.
Reported Overstatement: $330.0M.
Total Fines & Penalties: $160.0M.
Maximum Incarceration: No prison sentence.
Independent Auditor: PricewaterhouseCoopers LLP.
Primary Schemes: premature recognition.
Enforcement Status: ADJUDICATED (admitted).

OVERSTATEMENT $330.0M USD reported

TOTAL PENALTIES $160.0M Civil & disgorgement

PRISON TIME None No prison sentence

FIRST ACTION September 20, 2019 Initial proceeding

DETECTION METHOD Regulatory Enforcement & Forensic Audit Discovery source

PRIMARY REGULATOR Serious Fraud Office (UK) GB

ACCOUNTING MECHANICS FOR THIS CASE

HOW IT WAS DONE

In settled proceedings with admissions, the regulator found that The company manipulated its accounting records by executing schemes under premature-recognition. Financial reports filed with market regulators contained material misstatements that distorted true financial condition.

Applicable Scheme Classifications:

premature recognition →

CHARGED RESPONDENTS & OUTCOMES

1 NAMED PARTIES

Respondent	Role	Disposition & Judicial Outcome	Prison	Civil Penalty	O&D Bar
Tesco plc	ISSUER	Enforcement order and financial sanctions imposed.	None	$160.0M	No

RED FLAGS OBSERVED PRIOR TO DISCOVERY

EARLY SIGNALS

CASH FLOW TO NET INCOME DIVERGENCE 2017 Operating cash flow severely diverged from reported earnings

ENFORCEMENT ACTIONS & PRIMARY DOCKETS

PRIMARY SOURCE CITATIONS

foreign regulator ENF-2017-tesco

Filing Date: September 20, 2019

Enforcement Action: Tesco plc: £250M Premature Commercial Supplier Income Pull-Forward

Early recognition of commercial income from supplier promotions and rebates that had not yet been earned under contract terms.

Provisions: Securities & Corporate Law Compliance

Disposition: admitted View Primary Record ↗

TIMELINE OF EVENTS

CHRONOLOGY

June 1, 2017 • Misstatement

Material accounting irregularities commenced.

September 20, 2019 • Enforcement

Regulators commenced formal proceedings.

FINANCIAL CRIME REFERENCE SERIES

Cross-Domain Investigation Network

Major corporate accounting scandals frequently intersect with parallel financial crime domains. For violations outside financial reporting scope, explore the companion reference libraries in our open research series:

How Scams Work ↗

Consumer fraud, advance fee fraud, romance scams, phishing, social engineering, impersonation

How Money Laundering Works ↗

Placement, layering, integration, trade-based money laundering, smurfing, shell companies, bank secrecy

How Sanctions Evasion Works ↗

OFAC enforcement, dark fleet shipping, transshipment hubs, export control violations, circumvention networks

How Market Manipulation Works ↗

Spoofing, pump and dump schemes, wash trading, front running, insider trading, benchmark fixing

How Tax Evasion Works ↗

Offshore tax havens, transfer pricing abuse, carousel fraud, undeclared foreign accounts, aggressive tax shelters