The SEC filed a complaint relating to books and records and internal controls against Novo Nordisk, in respect of improper payments to Iraq under the U.N. Oil for Food Program. The SEC's complaint alleged that between 2000 – 2003, Novo Nordisk paid $1,437,946 in kickbacks and agreed to pay an additional $1,315,454 in kickbacks in connection with the sale of humanitarian goods to Iraq under the UN Oil for Food Program despite knowing that such payments were prohibited. The judgment ordered Novo Nordisk to disgorge $4,321,523 in profits plus $1,683,556 in pre-judgment interest, and pay a civil financial penalty of $3,025,066.