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FCPA Scorecard Blog

Foreign Corrupt Practices Act & Anti-Corruption

Israeli real estate conglomerate to pay $500,000 to resolve SEC allegations of FCPA books and records and internal controls violations

SEC FCPA

On March 9, an Israeli-based real estate conglomerate agreed with the SEC, pursuant to an administrative order, to pay $500,000 to resolve alleged violations of FCPA books and records and internal controls provisions. According to the order, the SEC found that from 2007 through 2012, Elbit Imaging Ltd (“Elbit” or the “Company”) and its Netherlands-based subsidiary, Plaza Centers NV, paid millions of dollars to third party consultants and agents for purported services related to a Romanian real estate project and the sale of a real estate asset portfolio in the United States. The SEC found that these payments were made with no indication that any services were actually provided.

Elbit did not admit or deny the SEC’s findings, but agreed to resolve this matter with a civil money penalty. In accepting Elbit’s offer for resolution, the SEC took into consideration Elbit’s self-reporting in 2016 to authorities in Romania and in the United States, as well as its full cooperation with the investigation, including the hiring of outside counsel to conduct an internal investigation, the findings of which were shared with the SEC. The SEC also considered the extensive remedial measures Elbit has put into place as a result of those findings and the Commission’s suggestions.

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