Texas-based Hyperdynamics Corporation announced in late September that it settled an investigation into FCPA books and records and internal controls violations conducted by the SEC. Although the U.S. Department of Justice (DOJ) previously announced in late May that it had closed its investigation without bringing charges, as Red Notice previously reported, the SEC pursued the enforcement through September's internal administrative order. According to its press release, Hyperdynamics agreed to pay a $75,000 penalty and consented to the entry of a cease-and-desist order without admitting or denying the SEC’s findings. The order references alleged defects in the company’s internal accounting and payment recording processes from July 2007 to October 2008, including failure to “record certain payments made by its subsidiary based in the Republic of Guinea” and shortcomings relating to accurately tracking and ensuring the propriety of the subsidiary’s expenditures. The settlement also takes into account Hyperdynamics’ remedial efforts and cooperation, including replacing its senior management team and board of directors. Additionally, the company implemented a compliance training program, increased its accounting staff and established a more stringent system for controlling the money flow to Guinea.