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Electronics Manufacturer to Pay $4.5 Million Penalty for Anti-Bribery Violations

Thursday, April 11, 2013
By Shawn McCausland
Sandler, Travis & Rosenberg Trade Report

The Securities and Exchange Commission announced recently that a major electronics manufacturer based abroad but listed on the New York Stock Exchange will pay $4.5 million in disgorgement and prejudgment interest to settle charges that it violated the books and records and internal control provisions of the Foreign Corrupt Practices Act. These violations related to improper payments to healthcare officials in Poland regarding the purchase of medical equipment. At press time there had been no news of any related action by the Department of Justice.

The SEC states that although the company failed to implement a system of FCPA compliance and internal controls, upon becoming aware of the violations of its subsidiary it conducted an internal audit and self-reported the results to the SEC and the DOJ. The company also cooperated with the SEC’s investigation and undertook numerous remedial measures, including installing new management of the subsidiary, improving its internal controls with respect to contract administration, making significant revisions to its global business principles policies, and establishing an anti-corruption training program that includes a certification process.

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