On March 23, 2016, the SEC instituted settled cease-and-desist proceedings against Novartis AG. According to the SEC: "These proceedings arise out of violations of the books and records and internal accounting controls provisions of the Foreign Corrupt Practices Act of 1977 (the 'FCPA') by respondent Novartis AG ('Novartis') concerning its pharmaceutical operations in China. From at least 2009 to 2013, certain employees and agents of Novartis subsidiaries conducting business in China engaged in transactions and provided things of value to foreign officials, principally healthcare professionals ('HCPs'). These payments took varied forms and were intended to influence the HCPs and thereby increase sales of Novartis pharmaceutical products. Employees and managers in the involved subsidiaries attempted to conceal the true nature of the transactions through the use of complicit third parties and by improperly recording the relevant transactions on the books and records of the respective subsidiaries, which were consolidated in the financial reports of Novartis. Examples include improperly recording the payments as legitimate expenses for travel and entertainment, conferences, lecture fees, marketing events, educational seminars, and medical studies. Novartis also failed to devise and maintain an effective system of internal accounting controls or an effective anti-corruption compliance program."