Action against Respondent, a gold mining company, for alleged violations of the books and records and internal controls provisions of the FCPA. According to the SEC, Respondent paid vendors and consultants without reasonable assurance that the transactions were consistent with their stated purpose and were not improper payments to government officials. In addition, Respondent allegedly used petty cash to make certain of these payments, which it failed to accurately describe in its books and records. The SEC further alleges that Respondent failed to adequately maintain internal accounting controls related to contracting, awarded a contract to a company preferred by government officials without following its own bidding and tendering procedures, and contracted with a consultant to facilitate contracts with government officials without conducting the heightened due diligence required by its policies and procedures. Respondent has agreed to pay a civil penalty of $950,000 and to a self-reporting undertaking.