Action against Respondent, a retailer, for alleged violations of the FCPA’s books and records and internal accounting controls provisions. According to the SEC, Respondent’s subsidiaries in Brazil, China, India, and Mexico lacked sufficient internal anticorruption controls and, as a result, employed third-party intermediaries who made improper payments to foreign government officials. The SEC further alleges that Respondent failed to adequately investigate allegations of corruption and mitigate known risks. Respondent has agreed to pay disgorgement of $119,647,735 and prejudgment interest of $25,043,437. Because of Respondent’s parallel settlement with the Department of Justice, the SEC did not impose a civil penalty.