Jump to content Jump to menu
Why Register?

Shearman FCPA Website: Cases Logo Shearman & Sterling LLP FCPA.Shearman.com: The One-Stop Resource on the Foreign Corrupt Practices Act

SEC v. American Bank Note Holographics, Inc.

 
:
American Bank Note Holographics - American Bank Note Holographics, Inc.
:
SEC Civil
:
July 18, 2001
:
SEC v. American Bank Note Holographics, Inc.
:
SEC v. American Bank Note Holographics, Inc., No. 01 CV 6453 (S.D.N.Y. 2001)
:
Manufacturing-Other/Multi
:
Saudi Arabia
:
1998; 1999
:
American Bank Note Holographics, Inc. ("ABNH") settled this action with the SEC without admitting or denying the following facts alleged in the SEC's order.

ABNH employed agents who were responsible for seeking out new business in various regions of the world. These agents were generally compensated on a commission basis for any business they generated for the company. In late 1998, one of ABNH's agents informed an ABNH employee of an opportunity to bid on a contract to produce holograms for Saudi Arabia. In an effort to win the contract, former ABNH officers authorized and directed an ABNH employee to wire $239,000 to a bank account for the benefit of one or more officials of that foreign government. The employee wired the money as instructed and ABNH accounted for this payment as a consulting fee. This $239,000 payment comprised nearly 40% of the contract's value and constituted an additional payment ABNH made for the purpose of influencing or affecting the acts or decisions of one or more of the foreign officials, or of the foreign government, in order to assist ABNH in obtaining or retaining business with the foreign government.
:
Anti-bribery (Issuer), Books and records (Issuer)
:
Civil penalty, Injunction/Cease and desist
:
Civil Penalty as a result of a Consent Agreement.
:
75,000
:
0
:
Domestic Concern, Issuer
:
U.S.
:
Contract Procurement/Retention
:
597,500
:
Wire/check
:
Sales Agent/Consultant
:
239,000
:
No
:
No