The SEC notched another FCPA settlement, continuing its steady pursuit and resolution of FCPA cases.  In the meantime, the Justice Department has been silent in the FCPA enforcement arena. 

In its latest settlement, Moog, Inc. (“Moog”), 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 and disgorge nearly $600,000, for a total of $1.7 million, to resolve FCPA charges arising out of bribes paid by its wholly owned Indian subsidiary, Moog Motion Controls Private Limited (Moog Motion Controls).

From 2020 to 2022, Moog 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 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.