Action against Respondent, an investment management firm, in connection with alleged violations of the Foreign Corrupt Practices Act.  According to the SEC, Respondent, through its subsidiary, partnered with a global financial services company to solicit business from state-owned financial institutions, in part by paying bribes through an intermediary to obtain investments from the financial institutions.  The SEC also alleged that Respondent lacked appropriate internal accounting controls with respect to the use of introducing brokers and other intermediaries in emerging markets. Respondent has agreed to pay disgorgement of $27,594,729 and prejudgment interest of $6,907,765.

SEC Order  

SEC Press Release