To resolve FCPA charges, a Florida-based engineering and construction firm, then known as The PBSJ Corporation (“PBSJ”), entered into a two-year deferred prosecution agreement with the SEC in which PBSJ agreed to pay $3.4 million in disgorgement, interest, and penalties. See Deferred Prosecution Agreementbetween SEC and PBSJ Corporation (Nov. 21, 2014). A former officer of PBSJ settled related charges on a neither-admit-nor-deny basis and agreed to pay a $50,000 civil money penalty. See Order Instituting Cease-and-Desist Proceedings, Hatoum, Exchange Act Release No. 74112 (Jan. 22, 2015). According to the SEC, the former officer authorized approximately $1.4 million in bribes, disguised as “consulting fees,” to a company owned by an official of Qatari Diar, a real estate company established by the Qatari sovereign wealth fund, to induce the official to provide confidential bid information that enabled a PBSJ subsidiary to bid for a hotel development project in Morocco and a light rail project in Qatar. The former officer also allegedly offered employment to another foreign official in exchange for assistance after PBSJ lost the bid for the hotel project. No payments actually were made before the scheme was discovered and PBSJ voluntarily disclosed it to U.S. authorities, but PBSJ earned approximately $2.9 million in profits because it was allowed to continue to work on the light rail project until a replacement could be found.