On September 28, the SEC announced a settlement with a Michigan-based medical device company to resolve the SEC’s charges of books and records and internal controls violations. According to the order, the company agreed to pay a $7.8 million penalty and accepted the imposition of an independent compliance consultant to resolve allegations that the company’s Indian subsidiary failed to maintain accurate books and records, and that the company’s internal controls were inadequate to identify possible improper payments related to the sale of its products in India, China, and Kuwait.

This is the second enforcement action the SEC has brought against the company in recent years. In a prior action in October 2013, the company paid over $13.2 million in penalties, disgorgement, and interest to settle charges of FCPA violations for bribing doctors, health care professionals, and other government-employed officials in Argentina, Greece, Mexico, Poland, and Romania.