Actions against Respondent, a technology company, and Defendants, two of Respondent’s former executives, for alleged violations of the FCPA’s anti-bribery, books and records, and internal accounting controls provisions.  According to the SEC, Respondent and Defendants paid bribes through a contractor to Indian officials to obtain operating licenses and construction permits.  The SEC alleges that Respondent and Defendants falsified documents in order to conceal the payments.  Respondent has agreed to pay disgorgement of $16,394,351, prejudgment interest of $2,773,017, and a civil penalty of $6,000,000.  Defendants have been charged in a parallel criminal action in the District of New Jersey.

SEC Litigation Release

SEC Complaint

SEC Order

SEC Press Release