The SEC stated: "From approximately 2000 through 2003, Ingersoll-Rand Company Limited ("Ingersoll-Rand") violated the books and records and internal controls provisions of the Foreign Corrupt Practices Act . . . when its subsidiaries entered into contracts involving approximately $1,507,845 in kickback payments in connection with sales of industrial equipment to Iraqi government entities under the United Nations Oil for Food Program."

The Court stated: "Defendant Ingersoll-Rand Company Limited . . . consented to the Court's jurisdiction over Defendant and the subject matter of this action; consented to entry of this Final Judgment without admitting or denying the allegations of the Complaint (except as to jurisdiction); waived findings of fact and conclusions of law; and waived any right to appeal from this Final Judgment."

The SEC stated that: "[It] filed Foreign Corrupt Practices Act books and records and internal controls charges against Ingersoll-Rand Company Ltd., a New Jersey-based industrial equipment company, in the U.S. District Court for the District of Columbia. The Commission's complaint alleges that from 2000 through 2003, four of Ingersoll-Rand's subsidiaries entered into contracts in which $963,148 in kickback payments were made and $544,697 in additional payments were authorized in connection with sales of humanitarian goods to Iraq under the U.N. Oil for Food Program (the "Program")."