Action against Respondent, a global electronics company, for alleged anti-bribery, anti-fraud, books and records, and internal accounting controls violations. According to the SEC, Respondent was involved in a bribery scheme whereby it provided a consulting position to a government official to induce him to assist Respondent in obtaining and retaining business from a state-owned airline. The SEC further alleges that Respondent materially overstated its pre-tax income and net income by backdating an agreement with the government airline. Finally, the SEC alleges that Respondent failed to devise and implement appropriate internal accounting controls with respect to the use of consultants and sales agents. Respondent has agreed to pay disgorgement of $126,900,000 and prejudgment interest of $16,299,018.93.