Computer software company PTC disclosed in an annual report last week that it is discussing a tentative $28.2 million settlement with the Department of Justice and the Securities and Exchange Commission to resolve an investigation of potential violations of the Foreign Corrupt Practices Act in China.

In its Form 10-K, issued Nov. 23, PTC said the tentative settlement for potential FCPA violations concerns “expenditures by our business partners in China and by our China business, including for travel and entertainment, that apparently benefited employees of customers regarded as state-owned enterprises in China.”

The FCPA investigation related to an SEC subpoena PTC received in May 2014. The company first disclosed settlement talks with the Justice Department and SEC in February 2014.

The company said it has recorded total liabilities of $28.2 million as a result of its agreement in principle with those agencies to settle the matter. This amount includes a liability of $13.6 million recorded in the third quarter of 2015 and an additional $14.6 million recorded in the fourth quarter of 2015.

“There can be no assurance that we will enter into final settlements on the agreed terms with these agencies or, if not, that the cost of any final settlements, if reached, would not exceed the existing accrual,” PTC said in the Form 10-K. “Further, any settlement or other resolution of this matter could have collateral effects on our business in China, the United States, and elsewhere.”

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