Action against Respondent, a technology company, for alleged violations of the books and records and internal controls provisions of the FCPA.  According to the SEC, Respondent’s subsidiary in Hungary provided resellers and other third parties with discounts that were used to fund improper payments to government officials.  The SEC further alleges that Respondent’s subsidiaries in Saudi Arabia and Thailand used resellers and other third parties to provide improper travel and gifts to government officials.  Finally, the SEC alleges that Respondent’s subsidiary in Turkey provided an excessive discount to a third-party contractor in connection with a government tender, and that Respondent’s records do not reflect the contractor having actually provided any services to the government.  Respondent has agreed to pay disgorgement of $13,780,733 and prejudgment interest of $2,784,418.  Respondent’s subsidiary in Hungary has agreed to pay a fine of $8,751,795 in a parallel criminal proceeding.

SEC Order

SEC Administrative Summary