On 8 April 2015, FLIR entered a Cease-And-Desist Order (the “Order”) which referred to the SEC’s acceptance of FLIR’s settlement offer. In the Order, the SEC found that FLIR had violated anti-bribery, books and records and internal controls provisions of the FCPA. The SEC stated that between 2008 and 2010, employees in FLIR’s Dubai office provided gifts of travel, entertainment and personal items (expensive watches) to government officials within the Saudi Arabia Ministry of Interior to obtain and retain business. In addition, the SEC found that FLIR failed to devise and maintain a sufficient system of internal accounting controls to prevent the provision and approval of the flights and the travel, and the falsification of FLIR’s books and records to conceal the conduct.