Or funds, off-the-books accounts, and systematic payments to commercial bribery,?> export controls violations,” and business consultants and other intermediaries—to facilitate embezzlement or self-dealing by company employees.” bribery. Payments were made in ways that obscured their purpose and the ultimate recipients of the money. In some Potential Reporting and Anti-Fraud Violations cases, employees obtained large amounts of cash from cash Issuers have reporting obligations under Section desks and then transported the cash in suitcases across inter- 13(a) of the Exchange Act, which requires issuers to file national borders. Authorizations for some payments were an annual report that contains comprehensive information placed on sticky notes and later removed to avoid any perma- about the issuer. Failure to properly disclose material infor- nent record. The company made payments totaling approxi- mation about the issuer’s business, including material rev- mately $1.36 billion through various mechanisms, including enue, expenses, profits, assets, or liabilities related to bribery $805.5 million as bribes and $554.5 million for unknown of foreign government officials, may give rise to anti-fraud purposes.””> The company was charged with internal controls and reporting violations under Sections 10(b) and 13(a) of and books and records violations, along with anti-bribery the Exchange Act. violations, and paid over $1.6 billion to resolve the case with For example, a California-based technology company authorities in the United States and Germany.” was charged with reporting violations, in addition to viola- The types of internal control failures identified in the tions of the FCPA’s anti-bribery and accounting provisions, above example exist in many other cases where companies when its bribery scheme led to material misstatements in its were charged with internal controls violations.”” A 2010 SEC filings.” The company was awarded contracts procured case against a multi