Action against Respondent, a medical technology corporation, for alleged violations of the FCPA’s books and records and internal accounting controls provisions.  According to the SEC, Respondent was unable to detect improper transactions and potential improper payments for sales in China, India, and Kuwait due to inadequate internal accounting controls, and Respondent’s Indian subsidiary maintained incomplete and inaccurate books and records.  Respondent has agreed to pay a civil penalty of $7.8 million.

SEC Order 

SEC Press Release