Israel-based Elbit Imaging Ltd. recently agreed to pay $500,000 to resolve SEC charges that it violated the books and records and internal controls sections of the FCPA. According to the SEC’s administrative order, Elbit and its indirect subsidiary, Plaza Centers NV, paid millions of dollars to third parties in connection with a real estate development project in Romania and the sale of real estate assets in the U.S. even though there was no evidence the third parties actually performed services for Elbit. The company “appears to have received significant credit for discovering, self-reporting, investigating, and remediating the conduct in question,” Neil Smith, who previously served as Senior Counsel in the SEC’s Enforcement Division and is now a partner at K&L Gates, told the Anti-Corruption Report. See our three-part series on in-house perspectives on third-party due diligence; “Right-Sizing and Risk Ranking” (May 24, 2017); “Information Gathering” (Jun. 7, 2017); and “Red Flags and Follow-Up” (Jun. 21, 2017).