On December 15, 2014, the SEC charged Bruker Corporation (Bruker) with violating the FCPA by making improper payments and paying for non-business-related travel expenses for Chinese government officials. Bruker, a Massachusetts-based global manufacturer of scientific instruments, paid approximately $2.4 million to settle the SEC’s charges. The SEC used an administrative cease-and-desist order to settle the case.

According to the SEC’s order, Bruker’s China subsidiaries made unlawful payments of approximately $230,000 to Chinese government officials who were employed by state owned entities that were Bruker customers. These payments included payments (i) for non-business travel (reimbursements to Chinese government officials for leisure travel to the United States and numerous European countries) and (ii) pursuant to collaboration and research agreements for which there was no legitimate business purpose. The SEC order found that Bruker violated the internal controls and books and records provisions of the FCPA. Bruker self-reported its misconduct and provided “significant” cooperation to the SEC.