2228. Rep, No. 95-114, at 7. 23 Section 13(b)(2)(B) of the Exchange Act, 15 US.C. § 78m(b)(2)(B). *4 Section 13(b)(7) of the Exchange Act, 15 U.S.C. § 78m(b)(7). I -NDIX 225 See Complaint, SEC v. Siemens AG, supra note 48; Criminal Information, United States v. Siemens AG, supra note 48, En d notes a Complaint, SEC v. Siemens AG, supra note 48; Criminal Information, United States v. Siemens AG, supra note 48; Press Release, U.S. Dept. of Justice, Siemens AG and Three Subsidiaries Plead Guilty to Foreign Corrupt Practices Act Violations and Agree to Pay $450 Million in Combined Criminal Fines (Dec. 15, 2008), available at http://www. justice.gov/opa/pr/2008/December/08-crm- 1105. html. 7 See, CG» Complaint, SEC v. Biomet, supra note 221 (bribes paid to Statoil, ASA, No. 06-cr-960 (S.D.N-Y. Oct. 13, 2006) (same), available at government healthcare providers in which phony invoices were used http: //wwwjustice.gov/ criminal /fraud/ fepa/ cases/statoil-asa-inc/10-13- to justify payments and bribes were falsely recorded as “consulting O9statoil-information.pdf. fees” or “commissions” in company’s books and records); Criminal 6 Although private companies are not covered by the books and records Information, United States v. Biomet, supra note 221 (same); SEC v. and internal controls provisions of the FCPA and do not fall within Alcatel-Lucent, supra note 48 (bribes paid to foreign officials to secure SEC’s jurisdiction, such companies generally are required by federal and telecommunications contracts where company lacked proper internal state tax laws and state corporation laws to maintain accurate books and controls and permitted books and records to falsified); United States v. records sufficient to properly calculate taxes owed. Further, most large Alcatel-Lucent, S.A., supra note 48 (same). private companies maintain their books and records to facilitate the 228 Complaint, SEC v. Daimler AG, supra note 48; Criminal Information, preparation of finan