After a seven-year investigation, IBM settled SEC charges that IBM had violated internal controls and books and records provisions of the Foreign Corrupt Practices Act. IBM agreed to disgorge $5.3 million and to pay a $2 million penalty and $2.7 million in prejudgment interest. IBM did not disclose the cost of the internal investigation, or whether the Department of Justice continues to investigate.

The SEC’s case included FCPA violations by IBM’s Chinese subsidiaries (“IBM-China”). IBM-China sold hardware, software, and other services to customers owned or controlled by the Chinese government. Those contracts sometimes called for IBM-China to provide offsite training to officials. IBM policies prohibited payment for side trips or stopovers unrelated to the training programs, and it required all travel to be pre-approved.