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Email On December 17, 2012, the Securities and Exchange Commission (“SEC”) announced that Allianz SE (“Allianz”), a German-based insurance and asset management company, had agreed to pay approximately $12.3 million to settle allegations that it violated the books and records and internal controls provisions of the Foreign Corrupt Practices Act (“FCPA”). Although the Allianz settlement does not represent one of the largest settlements in the history of FCPA enforcement, it is a noteworthy case in that it highlights the increasingly important role of whistleblowers in FCPA investigations as well as the SEC’s practice of seeking disgorgement for books and records violations without showing that the profits were earned as a result of the charged misconduct. https://www.cadwalader.com/resources/newsletters/fcpa-advisor/allianz-to-pay-12-3m-to-settle-secs-bribery-allegations