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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
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Richard L. Cassin
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Editor Emeritus

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Julie DiMauro
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Thomas Fox
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Bill Waite
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Russell A. Stamets
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Will it fly? Analogic proposes $1.6 million FCPA settlement to SEC

Imaging company Analogic Corp. said Wednesday it offered the Securities and Exchange Commission $1.6 million to settle a bribery probe involving the company’s Danish subsidiary.

Massachusetts-based Analogic said it “commenced discussions” with the SEC concerning a resolution of the matter.

The company said it accrued $1.6 million for the proposed settlement.

The SEC hasn’t publicly commented on the investigation or Analogic’s settlement offer.

Analogic makes airport security scanners and other magnetic resonance imaging equipment.

The SEC and DOJ don’t accept all FCPA settlement proposals. In August 2013, Avon proposed to the SEC and DOJ a settlement of $12 million. The feds rejected the proposal. Avon eventually paid $135 million in December 2014 to settle criminal and civil FCPA charges.

Analogic first disclosed the investigation involving Danish subsidiary BK Medical ApS and some of its foreign distributors in 2011.

The company said it hasn’t had any settlement discussions with the DOJ or the Danish government, which could still seek sanctions or penalties.

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Here’s the full FCPA disclosure from Analogic’s September 16, 2015 earnings release:

As initially disclosed in our Annual Report on Form 10-K for the fiscal year ended July 31, 2011, we identified certain transactions involving our Danish subsidiary BK Medical ApS, or BK Medical, and certain of its foreign distributors, with respect to which we have raised questions concerning compliance with law, including Danish law and the U.S. Foreign Corrupt Practices Act, and our business policies.

We have commenced discussions with the Securities and Exchange Commission concerning the resolution of the SEC inquiry into the matter and have proposed a payment of $1.6 million in settlement of such inquiry.

During the three months ended July 31, 2015, we accrued a $1.6 million charge in connection with our settlement proposal.

We are uncertain whether the U.S. Department of Justice or the Danish Government will seek to impose any sanctions or penalties against us and have not engaged in settlement discussions with either of these entities.

There can be no assurance that we will enter into any settlement with the SEC, the DOJ or the Danish Government, and the cost of any settlements or other resolutions of these matters could materially exceed our accruals.


Richard L. Cassin is the publisher and editor of the FCPA Blog. He can be contacted here.

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