On May 17, 2011, the SEC entered into a Deferred Prosecution Agreement ("DPA") with Tenaris S.A. ("Tenaris") in its first-ever use of the approach to facilitate and reward cooperation in SEC investigations. The agreement with Tenaris involves allegations that the global manufacturer of steel pipe products violated the Foreign Corrupt Practices Act ("FCPA") by bribing Uzbekistan government officials during a bidding process to supply pipelines for transporting oil and natural gas. Tenaris first discovered the FCPA violations by its personnel in Uzbekistan after it conducted a thorough, worldwide internal review of its operations and controls. In response to its findings, Tenaris informed the SEC and reviewed its controls and compliance measures, significantly enhancing its anti-corruption policies and practices. Under the terms of the DPA, the SEC will refrain from prosecuting the company in a civil action for its violations if Tenaris complies with certain undertakings. In addition to paying $5.4 million in disgorgement and prejudgment interest, Tenaris has agreed to, among other things, further enhance its policies, procedures, and controls to strengthen compliance with the FCPA and anti-corruption practices. Tenaris will implement due diligence requirements related to the retention and payment of agents, provide detailed training on the FCPA and other anti-corruption laws, require certification of compliance with anti-corruption policies, and notify the SEC of any complaints, charges, or convictions against Tenaris or its employees related to violations of any anti-bribery or securities laws. Finally, Tenaris agreed to continue to fully cooperate with the SEC in its investigation, as well as the Justice Department and any other law enforcement agency in connection with this case. In a Non-Prosecution Agreement with the Justice Department, Tenaris consented to pay an additional $3.5 million criminal penalty.