On July 31, 2009, the SEC filed a civil enforcement action against NSP, NSP’s CEO Douglas Faggioli, and NSP’s former CFO, Craig D. Huff, arising out of alleged bribes that NSP made to Brazilian customs officials in violation of the Foreign Corrupt Practices Act. The SEC brought only one cause of action against Messrs. Faggioli and Huff: for a violation of Sections 13(b)(2)(A) and (B) of the Securities Exchange Act of 1934 for failing to keep accurate books and records. In connection with a settlement of this enforcement action, NSP paid a penalty of $600,000, and Faggioli and Huff each paid $25,000 penalties. A number of industry commentators have noted that the SEC’s decision to bring this action against Messrs. Faggioli and Huff, who are not alleged to have been aware of the alleged bribes, imposed a de facto strict liability standard on these corporate executives.