SEC v. Jennings, Case No. 1:11-cv-00144 (Filed Jan. 24, 2011) is a settled FCPA action against Paul W. Jennings, the former CFO and CEO of Innospec, Inc. The complaint focuses on two key schemes. One involves Iraq and in part the U.N. Oil for Food Program while the other is based on bribes paid in Indonesia. In Iraq the company began paying bribes to sell its fuel additive as early as 2000. In 2001 it began paying bribes in connection with the U.N. program. In Iraq the company paid bribes, according to the court papers, totaling over $1.6 million and promised more than $880,000 in illegal payments. The company also paid for gifts, entertainment and travel. In Indonesia Innospec is alleged to have paid bribes from about 2000 through 2005 to obtain about $48.5 million in contracts from state owned oil and gas companies. Defendant Jennings is alleged to have been involved with some of the bribery schemes beginning in late 2004. He also failed to report the bribes involved in the U.N. program to the auditors after learning about them. Mr. Jennings settled the action by consenting to the entry of a permanent injunction prohibiting future violations of Exchange Act Sections 30A, and 13(b)(5) and from aiding and abetting Innospec’s violations of Exchange Act Sections 30A, 13(b)(2)(A) and 13(b)(2)(B). He also agreed to disgorge $116,092 along with prejudgment interest and to pay a civil penalty of $100,000. The settlement considers the cooperation of Mr. Jennings.