Civil FCPA Settlement by Dutch Electronics Giant Philips Continues Trend of “No-Charged Bribery Disgorgement” Cases

In the first FCPA settlement made public in 2013, Koninklijke Philips Electronics N.V. (Philips), a Dutch electronics company, has agreed to pay $4.5 million in disgorgement and prejudgment interest to resolve the SEC’s allegations that one of Philips’ subsidiaries that sells medical equipment, Philips Polska s.p z.o.o., violated the books and records provisions of the FCPA when its employees bribed Polish health care facility officials and failed to properly record the payments.

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