On 24 February 2015, Goodyear entered a Cease-and-Desist Order (the “Order”) which referred to the SEC’s acceptance of Goodyear’s settlement offer. In the Order, the SEC found that Goodyear subsidiaries in Kenya (Treadsetters Tyres Ltd) and Angola (Trentyre Angola Lda) had paid bribes to employees of government owned entities and private companies to increase tyre sales. These bribery payments were falsely recorded as legitimate business expenses in the subsidiaries’ books and records that were consolidated into Goodyear’s books and records, which breached FCPA’s books and records provisions . The SEC determined that Goodyear failed to implement adequate FCPA compliance controls at these subsidiaries to prevent and detect improper payments. When ascertaining whether to accept the settlement offer, the SEC took into consideration Goodyear’s co-operation with the SEC staff and the remedial efforts that had been undertaken.