Philips, a Dutch medical-device company, recently reached a $62.2‑million settlement with the SEC for books-and-records and internal accounting control violations of the FCPA resulting from the sale of medical equipment in China. The case marks the second time in a decade the SEC has charged Philips with FCPA violations. Philips was ordered to pay approximately $41.1 million in disgorgement and $6 million in prejudgment interest, as well as a $15‑million civil penalty. This article considers how companies may seek to review their internal accounting controls in light of the case, in the views of King & Spalding partner Alexander Koch and Vinson & Elkins partner Fry Wernick. See “Civil FCPA Settlement by Dutch Electronics Giant Philips Continues Trend of “No-Charged Bribery Disgorgement” Cases” (Apr. 17, 2013).