Lavish vacations for foreign officials across the globe in return for business form the basis for many of the government’s allegations against Diebold, Inc., an Ohio-based maker of ATM machines and security systems. Diebold settled with both the SEC and DOJ on October 22, 2013 and agreed to pay more than $48 million in fines, disgorgement and prejudgment interest for the alleged violations. The government alleged that $3 million in illicit payments were made on behalf of Diebold in China, Russia and Indonesia from 2005-2010. The DOJ charged the case as conspiracy to violate the anti-bribery provisions of the FCPA and a violation of the books and records provisions. The company agreed to retain a compliance monitor for 18 months, often a costly and unwelcome proposition. See “How to Find a Business-Minded Compliance Monitor and Minimize Reporting Requirements When Negotiating an FCPA Settlement (Part One of Three)” (Feb. 20, 2013); Part Two of Three (Mar. 6, 2013); Part Three of Three (Mar. 20, 2013)