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SEC: Sending Saudi Officials on 'World Tour' Was FCPA Violation

Bruce Carton | November 18, 2014

In case there was any ambiguity that companies may not send foreign government officials on a "world tour" in order to secure business, the SEC made that clear yesterday. In an administrative proceeding filed yesterday, the SEC sanctioned two former employees in the Dubai office of U.S.-based FLIR Systems Inc. for violating the FCPA via such conduct.

According to the SEC, Stephen Timms and Yasser Ramahi, who worked in sales at FLIR Systems Inc., were seeking to sell FLIR’s security cameras and binoculars to Saudi Arabia. The SEC claims that Timms and Ramahi first provided five Saudi Arabian officials with expensive luxury watches during meetings, and then later arranged for a number of key officials

to embark on what Timms referred to as a “world tour” of personal travel before and after they visited FLIR’s Boston facilities for a factory equipment inspection that was a key condition to...

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