Foreign Corrupt Practices Act Alert: FLIR Systems Agrees to Pay $9.5 Million to Settle SEC Charges of Violating the FCPA by Providing Gifts and Personal Travel to Saudi Arabian Officials

April 9, 2015

On April 8, 2015, the U.S. Securities and Exchange Commission issued a cease and desist order pursuant to which FLIR Systems, Inc. agreed to pay $8.5 million in disgorgement and prejudgment interest and a $1 million civil penalty to settle charges that the company violated the anti-bribery, books and records, and internal control provisions of the Foreign Corrupt Practices Act.  According to the SEC, FLIR employees provided Saudi Arabia Ministry of Interior (MOI) officials with personal travel and gifts between 2008 and 2010, in connection with business opportunities that resulted in profits of over $7 million.  The SEC further alleged that FLIR falsely recorded the improper expenses in its books and records, and that FLIR’s internal controls were insufficient to detect and prevent them.  The SEC previously had charged two FLIR employees with FCPA violations relating to this conduct.  FLIR consented to the SEC’s order without admitting or denying the findings.