Action against Respondent, a communication product company, for alleged violations of the FCPA’s books and records and internal accounting controls provisions.  According to the SEC, Respondent’s subsidiary provided discounts to distributors and resellers with the understanding that the discounts would be used to make cash payments to government officials who had influence over purchasing decisions.  The SEC further alleges that Respondent failed to maintain adequate accounting controls and lacked an effective anti-corruption compliance program with respect to its Chinese sales operations.  Respondent has agreed to pay disgorgement of $10,672,926, prejudgment interest of $1,833,410, and a civil penalty of $3.8 million.

SEC Order 

SEC Administrative Summary