SEC Settles Another Case Using the “Books and Records” and Internal Controls Provisions of the Foreign Corrupt Practices Act

The SEC today filed a consent decree in the U.S. District Court for the District of Columbia, alleging The Dow Chemical Company (Dow) violated the books and records and internal controls provisions of the FCPA in connection with an estimated $200,000 in improper payments made by an off-shore subsidiary to Indian government officials from 1996 through 2001. Without admitting or denying the allegations, Dow consented to pay a $325,000 civil penalty.

Here is a copy of the SEC’s press release and cease and desist order.

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