SEC Charges U.S.-Based Moog Inc. with FCPA Violations for Subsidiary’s Role in Indian Bribery Scheme
Moog Inc. agreed to pay $1.7 million to resolve SEC charges that its Indian subsidiary violated the FCPA by bribing officials to secure business and influence public tenders.
Moog Inc. violated the FCPA's recordkeeping and internal accounting control provisions through its subsidiary, Moog Motion Controls Private Limited. Between 2020 and 2022, the company used third-party agents and distributors to funnel bribes to Indian officials to win business and influence public tenders. To resolve the matter, Moog agreed to pay a $1.1 million civil penalty plus nearly $600,000 in disgorgement and prejudgment interest.
Moog Inc., a New York-based manufacturer, resolved SEC charges that its Indian subsidiary, Moog Motion Controls Private Limited, violated the Foreign Corrupt Practices Act (FCPA) from 2020 through 2022. The subsidiary bribed various Indian officials to win business and influence public tenders by funneling payments through third-party agents and distributors. These actions led to violations of the FCPA’s recordkeeping and internal accounting control provisions. To settle the charges, Moog consented to a cease-and-desist order without admitting or denying the findings. The company agreed to pay a $1.1 million civil penalty alongside nearly $600,000 in disgorgement and prejudgment interest. This enforcement action highlights the critical need for international issuers to maintain robust compliance and oversight regarding third-party payments.
Exhibits & Attached Documents (1)
Extracted insights
- $1.10M $1.1 million $1M–$10M
- $600K $600,000 $100K–$1M
- person cash bribes
- person charles e. cain
- agency chief of the sec enforcement division’s fcpa unit
- person indian officials
- company moog inc.
- person moog motion controls employees
- company moog motion controls private limited
- agency sec’s investigation
- agency Securities and Exchange Commission
- agency the entry of the sec’s order
- Securities and Exchange Commission announced Moog Inc. agreed to pay a civil penalty of $1.1 million
- Moog Inc. agreed to pay a civil penalty of $1.1 million
- Moog Inc. violated the Foreign Corrupt Practices Act
- Moog Motion Controls Private Limited paid bribes
- Moog Motion Controls employees bribed Indian officials
- Moog Motion Controls employees offered cash bribes
- Charles E. Cain is Chief of the SEC Enforcement Division’s FCPA Unit
- Moog violated the recordkeeping and internal accounting controls provisions of the FCPA
- Moog consented to the entry of the SEC’s order
- Moog agreed to pay disgorgement and prejudgment interest totaling nearly $600,000
- Moog agreed to pay a civil penalty of $1.1 million
- SEC’s investigation was conducted by Irene Gutierrez, Michelle L. Ramos, Maria F. Boodoo, and Tracy L. Price
The Securities and Exchange Commission today announced that Moog Inc., a New York-based global manufacturer of motion controls systems for aerospace, defense, industrial and medical markets, agreed to pay a civil penalty of $1.1 million to resolve the SEC’s charges that it violated the Foreign Corrupt Practices Act (FCPA) arising out of bribes paid by its wholly owned Indian subsidiary, Moog Motion Controls Private Limited (Moog Motion Controls). The SEC’s order finds that, from 2020 through 2022, Moog Motion Controls employees bribed a variety of Indian officials to win business and also used a variety of schemes to make the improper payments, including by funneling them through third-party agents and distributors. These same Moog Motion Controls employees also offered cash bribes to Indian officials in an attempt to cause public tenders in India to favor Moog’s products and exclude competitors. “The SEC’s action against Moog highlights the need for issuers operating internationally to have appropriate compliance and internal accounting controls over third parties and third-party payments, as weaknesses in those systems heighten corruption risk,” said Charles E. Cain, Chief of the SEC Enforcement Division’s FCPA Unit. The SEC’s order found that Moog violated the recordkeeping and internal accounting controls provisions of the FCPA. Without admitting or denying the SEC’s findings, Moog consented to the entry of the SEC’s order requiring it to cease and desist from committing or causing any future violations and agreed to pay disgorgement and prejudgment interest totaling nearly $600,000, and a civil penalty of $1.1 million. The SEC’s investigation was conducted by Irene Gutierrez, Michelle L. Ramos, Maria F. Boodoo, and Tracy L. Price of the SEC’s FCPA Unit.
The Securities and Exchange Commission today announced that Moog Inc., a New York-based global manufacturer of motion controls systems for aerospace, defense, industrial and medical markets, agreed to pay a civil penalty of $1.1 million to resolve the SEC’s charges that it violated the Foreign Corrupt Practices Act (FCPA) arising out of bribes paid by its wholly owned Indian subsidiary, Moog Motion Controls Private Limited (Moog Motion Controls). The SEC’s order finds that, from 2020 through 2022, Moog Motion Controls employees bribed a variety of Indian officials to win business and also used a variety of schemes to make the improper payments, including by funneling them through third-party agents and distributors. These same Moog Motion Controls employees also offered cash bribes to Indian officials in an attempt to cause public tenders in India to favor Moog’s products and exclude competitors. “The SEC’s action against Moog highlights the need for issuers operating internationally to have appropriate compliance and internal accounting controls over third parties and third-party payments, as weaknesses in those systems heighten corruption risk,” said Charles E. Cain, Chief of the SEC Enforcement Division’s FCPA Unit. The SEC’s order found that Moog violated the recordkeeping and internal accounting controls provisions of the FCPA. Without admitting or denying the SEC’s findings, Moog consented to the entry of the SEC’s order requiring it to cease and desist from committing or causing any future violations and agreed to pay disgorgement and prejudgment interest totaling nearly $600,000, and a civil penalty of $1.1 million. The SEC’s investigation was conducted by Irene Gutierrez, Michelle L. Ramos, Maria F. Boodoo, and Tracy L. Price of the SEC’s FCPA Unit.