Smith & Wesson Holding Corporation (“Smith & Wesson”) settled charges brought by the Securities Exchange Commission alleging violations of the Foreign Corrupt Practices Act (“FCPA”).  See Smith & Wesson Holding Corp., Exchange Act Release No. 72,678 (July 28, 2014).  The SEC found that in 2008, Smith & Wesson retained a Pakistani agent to assist it in obtaining a contract with a Pakistani police department, and in connection with that effort, Smith & Wesson authorized the agent to provide more than $11,000 worth of guns as gifts to Pakistani police officials and to make additional cash payments.  Smith & Wesson ultimately obtained a contract to sell approximately 500 pistols to the police department, for which it received a profit of about $107,000.  The SEC also found that Smith & Wesson authorized third‑party agents to make improper payments in Bangladesh, Indonesia, Nepal, Turkey, but the company either failed to win or to consummate contracts in those countries.  Smith & Wesson agreed to pay $107,852 in disgorgement, $21,040 in prejudgment interest, and a $1.906 million penalty.  Notably, the company was allowed to settle the charges without admitting or denying the SEC’s findings; the Commission publicly stated that it intended the matter to serve as a “wake-up call for small and medium-size businesses that want to enter into high-risk markets and expand their international sales.”