On March 18, 2011, the SEC filed a complaint against International Business Machines Corporation. According to the complaint: "During the period from 1998 through 2009, in violation of the Foreign Corrupt Practices Act of 1977 ('FCPA'), employees of certain of International Business Machines Corporation's ('IBM' or the 'Company') subsidiaries and a majority-owned joint venture provided cash payments, improper gifts, as well as improper travel and entertainment to government officials in South Korea and China."

On March 18, 2011, the SEC announced that it filed a settled Foreign Corrupt Practices Act enforcement action against International Business Machines Corporation ("IBM"), charging IBM "with violating the books and records and internal control provisions of the Foreign Corrupt Practices Act of 1977... as a result of the provision of improper cash payments, gifts, and travel and entertainment to government officials in South Korea and China." According to the SEC: "Without admitting or denying the SEC's allegations, IBM consented to the entry of a final judgment that permanently enjoins the company from violating the books and records and internal control provisions of the FCPA, codified as Sections 13(b)(2)(A) and 13(b)(2)(B) of the Securities Exchange Act of 1934. IBM also agreed to pay disgorgement of $5,300,000, $2,700,000 in prejudgment interest, and a $2,000,000 civil penalty."

On July 25, 2013, Federal District Judge Richard J. Leon entered final judgment as to International Business Machines Corporation ("IBM") pursuant to the consent of IBM.