Bruker Corporation (Bruker), a Massachusetts-based life sciences company, settled FCPA books-and-records charges with the SEC on a neither admit nor deny basis. See Order Instituting Cease-and-Desist Proceedings, Bruker Corp., Exchange Act Release No. 73835 (Dec. 15, 2014). According to the SEC’s allegations, from 2005 through 2011, Bruker’s Chinese operations paid a series of bribes to officials of a Chinese state-owned corporation. Bruker’s alleged improper payments fell into two categories: (1) a series of non-business-related travel and side trips during business-related travel provided to Chinese officials at state-owned enterprises; and (2) a series of “collaboration agreements” with Chinese officials at state-owned enterprises that did not specify what work the officials were to perform. In both instances, the Chinese officials were in the position to approve, and did approve, contracts between the Chinese state-owned entities and Bruker’s China operations. The SEC stated that Bruker received credit for its “extensive, thorough, and real-time cooperation,” including promptly self-reporting the potential misconduct, hiring independent counsel to conduct an internal investigation, implementing new remedial measures, providing real time reports of its investigative findings, sharing its witness interview summaries as well as its analysis of important documents, and expanding its investigation based on the SEC’s request.