Action against Respondent, a networking equipment product and service company, for alleged violations of the books and records and internal controls provisions of the FCPA. According to the SEC, sales employees of Respondent’s foreign subsidiaries agreed with third-party channel partners to increase the incremental discount provided to customers through those partners without passing the discounts on to customers. The SEC alleges that the channel partners diverted the discounts for personal and marketing expenses, including trips for government officials. According to the SEC, Respondent failed to accurately record the discounts and travel and marketing expenses in its books and records, and failed to devise and maintain a system of internal accounting controls sufficient to prevent and detect off-book accounts, and unauthorized customer trips. Respondent has agreed to pay $4,000,000 in disgorgement, $1,245,018 in prejudgment interest, and a civil penalty of $6,500,000.