Diebold, Inc., an Ohio-based manufacturer of ATMs and bank security systems, has settled an FCPA matter with the SEC and the Department of Justice (DOJ) for a combined total of $48.1 million. The SEC and DOJ alleged that, between 2005 and 2010, employees of Diebold’s subsidiaries in Indonesia and China provided gifts, entertainment, and trips to influence employees of state-owned banks to purchase Diebold products. The SEC and DOJ also alleged that employees of Diebold’s Russian subsidiary paid $1.2 million through a distributor to employees of private banking customers to obtain business from those banks. While not a violation of the FCPA anti-bribery provision, because these payments did not involve government officials, DOJ and SEC alleged that Diebold employees knowingly recorded these payments to individuals at private banks inaccurately as legitimate business expenses, and thus that Diebold committed both criminal and civil violations of the FCPA’s books and records provisions. Diebold agreed to pay $22.9 million in disgorgement and prejudgment interest to the SEC, and a fine of $25.2 million to DOJ. See Complaint, SEC v. Diebold, Inc., No. 13-1609 (D.D.C. Oct. 22, 2013), Information, United States v. Diebold, Inc., No. 13-cr-464 (N.D. Ohio Oct. 22, 2013).