FLIR FCPA Action Highlights Continued Focus on Penalizing Improper Expenditures for Government Officials

April 13, 2015

FLIR Systems, Inc. (“FLIR”), a publicly traded company based in Oregon, agreed to pay approximately $9.5 million to settle allegations of violations of the Foreign Corrupt Practices Act (“FCPA”) on April 8, 2015. The U.S. Securities and Exchange Commission’s (“SEC”) order found that FLIR provided improper travel and gifts to Saudi Arabian government officials, including a “world tour” for certain officials, in exchange for contracts worth more than $7 million, and that these expenses were not properly recorded in the company’s books and records. Notably, the overwhelming majority of the $9.5 million settlement resulted from disgorgement of profits rather than civil penalties, reflecting significant mitigation awarded for the company’s voluntary disclosure of violations.

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