On December 17, 2012 the Commission accepted respondent's settlement offer and imposed a cease-and-desist order and civil penalty. The SEC alleged that Allianz SE violated the Foreign Corrupt Practices Act through the actions of its Indonesian majority-owned subsidiary, PT Asuransi Allianz Utama. According to the SEC, "Utama managers made improper payments to employees of state-owned entities in Indonesia in order to obtain and retain business.... As a result of improper payments of approximately $650,626 to agents and employees of state-owned entities and others, Allianz realized $5,315,649 in profits."

On December 17, 2012, the SEC announced that it charged Germany-based insurance and asset management company Allianz SE ("Allianz") with violating the books and records and internal controls provisions of the Foreign Corrupt Practices Act ("FPCA") for improper payments to government officials in Indonesia during a seven-year period. According to the SEC's order instituting settled administrative proceedings against Allianz, the misconduct occurred from 2001 to 2008 while the company's shares and bonds were registered with the SEC and traded on the New York Stock Exchange. The SEC's order found that Allianz violated the books and records and internal controls provisions of the FCPA. Without admitting or denying the findings, Allianz agreed to cease and desist from further violations and pay more than $12.3 million to settle the SEC's charges.