On September 24, 2012, the SEC filed a civil complaint against Tyco International Ltd. According to the complaint: "This matter concerns violations by Tyco International Ltd. ('Tyco') of the books and records, internal controls, and anti-bribery provisions of the Foreign Corrupt Practices Act ('FCPA').... The FCPA misconduct [voluntarily] reported by Tyco showed that Tyco's books and records were misstated as a result of at least twelve different, post-injunction illicit payment schemes occurring at Tyco subsidiaries across the globe. The schemes frequently entailed illicit payments to foreign officials that were inaccurately recorded so as to conceal the nature of the payments." Countries where alleged FCPA violations took place include: Turkey, China, Croatia, India, Libya, Saudi Arabia, Serbia, Syria, the United Arab Emirates, Mauritania, the Congo, Niger, Madagascar, Thailand, Malaysia, Egypt, and Poland.

On September 24, 2012, the SEC published a litigation release regarding this matter. According to the release Tyco International Ltd. agreed to "pay over $13 million in disgorgement and prejudgment interest to settle the charges."

On September 24, 2012, the SEC charged Tyco International Ltd. with violating the Foreign Corrupt Practices Act when subsidiaries arranged illicit payments to foreign officials in 12 different counties, including Germany and China. The Commission alleges that as a result of these payment schemes, Tyco's books and records were misstated and it failed to devise and maintain internal controls sufficient to detect the violations.

On June 17, 2013, Federal District Judge Richard J. Leon entered final judgment against Tyco International Ltd pursuant to the consent of Tyco International Ltd.