In SEC v. Sharef, No. 11-9073 (S.D.N.Y. Feb. 19, 2013), the SEC alleged that seven former executives at Siemens AG and its subsidiaries had participated in an extensive scheme to bribe government officials in Argentina. One defendant, Herbert Steffen, is a German national who had served as CEO of Siemens’ Argentinean subsidiary prior to the events alleged in the complaint. The SEC charged Steffen with violating the FCPA’s anti-bribery provision and with aiding and abetting violations by Siemens of the FCPA provision requiring public companies to maintain accurate books and records. According to the SEC, Steffen pressured the CFO of Siemens Argentina to authorize bribes to Argentinean officials. The CFO of Siemens Argentina allegedly authorized bribes, but only after seeking guidance from superiors at Siemens. The Siemens Argentina CFO allegedly also signed quarterly and annual certifications of the company’s financials that were false because of the bribes, which were concealed), which were presented to the company’s auditors and resulted in the parent corporation, Siemens AG, making false SEC filings. The court granted a motion to dismiss for lack of personal jurisdiction as to Steffen, however, reasoning that his role was too attenuated from the SEC filings because he did not authorize the bribes and was neither involved in the alleged cover up nor had any awareness of it.