Massachusetts-based medical device manufacturer Analogic Corp. and its wholly-owned Danish subsidiary, BK Medical ApS, will pay nearly $15 million to settle parallel civil and criminal actions involving Foreign Corrupt Practices Act violations. An SEC investigation found that BK Medical engaged in hundreds of sham transactions with distributors that funneled about $20 million to third parties, including individuals in Russia and apparent shell companies in Belize, the British Virgin Islands, Cyprus, and Seychelles. According to the SEC’s order, from at least 2001 through 2011, at the direction of its distributors, BK Medical participated in hundreds of highly suspicious transactions that posed a significant risk of bribery or other improper conduct, such as embezzlement or tax evasion. SEC
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