Sightseeing trips around the world for employees of Chinese state-owned enterprises and sham collaboration agreements with those SOEs form the basis the SEC’s FCPA settlement with Bruker Corp., a Massachusetts-based manufacturer of scientific instruments.  The case features many of the recurring elements from past enforcement actions: employees of state-owned entities who may not intuitively be thought of as foreign officials; all-expenses-paid leisure trips disguised as business trips for officials responsible for purchasing decisions; weak compliance measures, including a failure to translate training presentations and hotlines into Chinese and the lack of an independent compliance or internal audit function in China; and no charges based on the anti-bribery provisions of the FCPA.