In a rare individual FCPA settlement with a sitting CEO, the SEC has resolved books and records allegations against Ignacio Cueto Plaza for $75,000. Cueto, the head of LAN Airlines, neither admitted nor denied the allegations in the SEC’s order regarding the funneling of $1.15 million to an Argentinian consultant in 2006 to pay off union leaders during a labor dispute. We dissect the settlement, which includes a surprising level of detail about training and may be a precursor to future actions related to LAN’s compliance program breakdown. See also “SEC Sanctions Two FLIR Systems Employees for Bribing Saudi Officials” (Nov. 19, 2014).