Originally published in Law360, New York (March 20, 2012, 1:18 PM ET).

On Feb. 24, 2012, the U.S. Securities and Exchange Commission charged three executives of Noble Corporation, a Swiss oil services company, with violating the Foreign Corrupt Practices Act. The SEC accused Noble’s former CEO and the company’s current division manager in Nigeria of arranging hundreds of thousands of dollars in bribes from 2003 to 2007. According to the SEC, the bribes were to induce Nigerian customs officials to grant new temporary permits and extensions to allow Noble’s oil rigs to remain in the country improperly. Both individuals are disputing the charges.

Of perhaps even more interest, the SEC also charged Noble’s former controller and director of internal audit with aiding and abetting these alleged bribes and with directly violating the FCPA’s internal controls and books and records provisions. In particular, the SEC contended that the former audit director’s actions allowed the bribes to be falsely recorded as legitimate operating expenses on Noble’s books, records and accounts. Unlike the other two charged executives, the former audit director has agreed to settle with the SEC and pay a $35,000 civil penalty.