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SEC v. David Pillor

 
:
InVision - Pillor, David
:
SEC Civil
:
August 15, 2006
:
SEC v. David Pillor
:
SEC v. David M. Pillor, No. 1:06-C-4906 (N.D. Cal. 2006)
:
The SEC alleged that Pillor failed to devise and maintain an adequate system of internal controls to prevent violations of the FCPA. These allegations are in contrast to the more frequent allegations that individuals participated in improperly recording transactions in an issuer's books and records.
:
Infrastructure-Ports
:
China, Philippines, Thailand
:
2002; 2003; 2004
:
Officials of the government of the Philippines; Filipino political parties; Officials of Chinese state-owned general construction company; Officials of Chinese state-owned importing company; Officials of the government of Thailand; Thai political parties
:
Pillor settled this action with the SEC without admitting or denying the following facts alleged in the SEC's complaint:

Pillor was the Senior Vice President for Sales and Marketing and a member of the board of directors of InVision Technologies, Inc. InVision is a manufacturer of explosive detection systems used at airports. In June 2002 through June 2004, payments were made by InVision's sales agents and distributors to foreign officials in each of China, Thailand, and the Philippines to secure or retain business for InVision. The DOJ found that there was a "high probability" that senior employees at InVision were aware of the payments but took no action to determine their legality. Pillor, specifically, failed to devise and maintain a system of internal controls adequate to detect and prevent InVision's violations of the FCPA. He also indirectly caused the falsification of the company's books and records. On August 15, 2006, the SEC and Pillor settled. Without admitting or denying the allegations, Pillor agreed to pay a $65,000 civil penalty and to the entry of a permanent injunction against future violations.
:
Internal controls (Issuer)
:
Civil penalty, Injunction/Cease and desist
:
Civil penalty of $65,000 and permanent injunction against future violations.
:
65,000
:
0
:
Director of Issuer, Officer of Issuer
:
Director, Senior Sales
:
U.S.
:
Contract Procurement/Retention
:
41,300,000
:
Cash, Gifts, Travel
:
Customs Broker or Agent/Consultant
:
203,000
:
China, Philippines, Thailand
:
Yes
:
No