The Securities and Exchange Commission accused a subsidiary of a prominent US asset manager of violating the FCPA’s internal controls provision by bribing Libyan officials in order to secure investments by state-owned financial institutions that earned the company over $31 million. The settlement follows a June 2018 non-prosecution agreement between the prominent US asset manager and the Department of Justice pursuant to which it agreed to pay $64.2 million regarding the same conduct. The settlement with the SEC includes $27.6 million in disgorgement, plus interest, but not a civil penalty based on the DOJ’s imposition of a $32.6 million criminal penalty.
SEC press release | SEC order | DOJ press release | Non-prosecution agreement