On March 9, an Israeli-based real estate conglomerate (the company) agreed with the SEC, pursuant to an administrative order, to pay $500,000 to resolve alleged violations of FCPA books and records and internal controls provisions. According to the order, the SEC found that from 2007 through 2012, the company and its Netherlands-based subsidiary paid millions of dollars to third party consultants and agents for purported services related to a Romanian real estate project and the sale of a real estate asset portfolio in the United States. The SEC found that these payments were made with no indication that any services were actually provided.

The company did not admit or deny the SEC’s findings, but agreed to resolve this matter with a civil money penalty. In accepting the company’s offer for resolution, the SEC took into consideration the company’s self-reporting in 2016 to authorities in Romania and in the U.S., as well as its full cooperation with the investigation, including the hiring of outside counsel to conduct an internal investigation, the findings of which were shared with the SEC. The SEC also considered the extensive remedial measures the company has put into place as a result of those findings and the Commission’s suggestions.