Defendant Name: Analogic Corporation

Defendant Type: Public Company
SIC Code: 3812
CUSIP: 03265720

Initial Case Details

Legal Case Name In the Matter of Analogic Corporation and Lars Frost
First Document Date 21-Jun-2016
Initial Filing Format Administrative Action
File Number 3-17305
Allegation Type Foreign Corrupt Practices Act
AAER 3784

Violations Alleged

Exchange Act
Sec 13(b)(2)(A)
Sec 13(b)(2)(B)
Additionally, Lars Frost is alleged to have caused Analogic Corporation's violation of Sec 13(b)(2)(A) of the Exchange Act.
Lars Frost is alleged to have caused Analogic Corporation's violation of Sec 13(b)(2)(B) of the Exchange Act.


First Resolution Date 21-Jun-2016
Headline Total Penalty and Disgorgement

See Related Documents

Related Documents:

2016-126 21-Jun-2016 Press Release--Administrative Proceeding
SEC Charges Medical Device Manufacturer with FCPA Violations
On June 21, 2016, the SEC announced that "Massachusetts-based medical device manufacturer Analogic Corp. and its wholly-owned Danish subsidiary have agreed to pay nearly $15 million to settle parallel civil and criminal actions involving Foreign Corrupt Practices Act (FCPA) violations. And SEC investigation found that Analogic's Danish subsidiary, BK Medical ApS, engaged in hundreds of sham transactions with distributors that funneled about $20 million to third parties, including individuals in Russia and apparent shell companies in Belize, the British Virgin Islands, Cyprus, and Seychelles."
34-78113 21-Jun-2016 Administrative Proceeding
Order Instituting Cease-and-Desist Proceedings Pursuant to Section 21C of the Securities Exchange Act of 1934, Making Findings, and Imposing a Cease-and-Desist Order
On June 21, 2016, the SEC instituted settled cease-and-desist proceedings against Analogic Corporation and Lars Frost. According to the SEC: "This matter concerns violations of the books and records and internal accounting controls provisions of the Foreign Corrupt Practices Act ('FCPA') by Analogic, a medical device manufacturer headquartered in Peabody, Massachusetts, and by Lars Frost, a citizen and resident of Denmark and the former Chief Financial Officer of Analogic's wholly-owned Danish subsidiary, BK Medical ApS ('BK Medical'), which sells ultrasound equipment. From at least 2001 through early 2011, BK Medical participated in hundreds of highly suspicious transactions at its distributors' direction which posed a significant risk of bribery or other improper conduct. The suspicious transactions involved BK Medical's distributor in Russia, as well as, to a lesser extent, its distributors in Ghana, Israel, Kazakhstan, Ukraine, and Vietnam. The transactions routinely involved fictitious invoices issued by BK Medical at inflated prices, overpayments to BK Medical from the distributors against the inflated invoices, and subsequent payments by BK Medical out of the distributors' excess funds to unknown third parties all over the world for unknown reasons. In short, for at least nine years, BK Medical acted as a conduit for its distributors to funnel money to parties, and for reasons, unknown to BK Medical. Approximately $20 million flowed through BK Medical from these distributors, with over $16 million from BK Medical's Russian distributor." The SEC stated that it was not imposing a civil penalty on Analogic because BK Medical, a wholly-owned subsidiary of Analogic, entered into a non-prosecution agreement with the U.S. Department of Justice under which BK Medical paid a $3,402,000 fine.

Other Defendants in Action: