Action against Respondent, a pharmaceutical company, for alleged violations of the FCPA’s books and records and internal accounting controls provisions.  According to the SEC, Respondent, through its subsidiaries in Kazakhstan and the Middle East, paid bribes to foreign officials in Central Asia, the Levant, and the Persian Gulf region to increase sales of Respondent’s products and falsified expense reports in order to conceal these payments.  The SEC further alleges that Respondent’s distributors bid on government contracts in Kazakhstan with predetermined discounts that were then used to pay foreign officials who agreed to improperly influence the recipients of the contracts.  Respondent has agreed to pay disgorgement of $17,531,666, prejudgment interest of $2,674,479, and a civil penalty of $5 million.

SEC Order 

SEC Press Release