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• Propose internal controls that should have been in place to prevent an ethical violation for the case study provided below.

Luckin Coffee Agrees to Pay $180 Million Penalty to Settle Accounting Fraud Charges

FOR IMMEDIATE RELEASE 2020-319

Washington D.C., Dec. 16, 2020

The Securities and Exchange Commission today charged China-based company Luckin Coffee Inc. with defrauding investors by materially misstating the companys revenue, expenses, and net operating loss in an effort to falsely appear to achieve rapid growth and increased profitability and to meet the companys earnings estimates. Luckin, whose American Depositary Shares traded on Nasdaq until July 13, 2020, has agreed to pay a $180 million penalty to resolve the charges.

The SECs complaint alleges that, from at least April 2019 through January 2020, Luckin intentionally fabricated more than $300 million in retail sales by using related parties to create false sales transactions through three separate purchasing schemes. According to the complaint, certain Luckin employees attempted to conceal the fraud by inflating the companys expenses by more than $190 million, creating a fake operations database, and altering accounting and bank records to reflect the false sales.

The complaint further alleges that the company intentionally and materially overstated its reported revenue and expenses and materially understated its net loss in its publicly disclosed financial statements in 2019. For example, Luckin allegedly materially overstated its reported revenue by approximately 28% for the period ending June 30, 2019, and by 45% for the period ending Sept. 30, 2019, in its publicly disclosed financial statements. The complaint alleges that during the period of the fraud, Luckin raised more than $864 million from debt and equity investors. After Luckins misconduct was discovered in the course of the annual external audit of the companys financial statements, Luckin reported the matter to and cooperated with SEC staff, initiated an internal investigation, terminated certain personnel, and added internal accounting controls.