Settlements

ST-149
Electronic Data Systems Corporation (A.T. Kearney Ltd. - India)
Electronic Data Systems Corporation
United States
Securities and Exchange Commission
India
2007
09/25
Unknown
Legal Person
Civil
Consent to Cease-and-Desist Order
Disgorgement of Profits, Prejudgment Interest
$490,902.00
$358,800
$132,102
$0
$0
Art.16, Art.26
Art. 1, Art. 2, Art. 8
Falsification of books and records, Disclosure violations, Regulation violations
No admission or denial of allegations
Yes
According to the US Department of Justice Report to Congress, Appendix C "Summaries of Foreign Corrupt Practices Act Enforcement Actions by the United States, January 1, 1998 - September 30, 2010," Electronic Data Systems Corporation, at 81-82: Misconduct in India, 2001-2003; EDS's former Indian subsidiary, A.T. Kearney Ltd. - India (ATKI) alleged to have made at least $720,000 in illicit payments to high-level employees of two Indian state-owned enterprises threatened in order to retain business with those enterprises; ATKI made the payments at the direction of Srninivasan, ATKI's president, after the officials of the state-owned enterprises threatened to cancel the contracts with ATKI. These bribes allowed EDS to recognize over $7.5 million in revenue from the Indian companies' contracts after ATKI began paying the bribes. Settlement amounts: $70,000 civil penalty (Srinivasan), $358,800 disgorgement and $132,102 prejudgment interest (EDS / ATKI-related penalties). Resulting civil enforcement/administrative actions: In the Matter of Electronic Data Systems Corporation (September 25, 2007); SEC v. Chandramowli Srinivasan (D.D.C., September 25, 2007).