InVision Technologies, Inc. / David Pillor
InVision Technologies, Inc.
United States
Securities and Exchange Commission
China, Philippines, Thailand
Consent to Permanent Injunction
Civil Penalty
Art.16, Art.27
Art. 1, Art. 8
Falsification of books and records, Aiding and abetting InVision's internal controls violations
No admission or denial of allegations
According to the US Securities and Exchange Commission's Litigation Release, the agency alleged that "during the period from late 2001 through June 2004, InVision completed sales to airports in China, the Philippines, and Thailand. In the course of these transactions, Pillor received e-mail messages from his Asian regional sales manager that suggested that InVision's overseas sales agents and distributors intended to make improper payments or other gifts to foreign government officials, in violation of the FCPA. InVision subsequently paid invoices to its agents and distributors in China and the Philippines and improperly recorded the payments as legitimate business expenses. InVision's FCPA violations occurred, in part, because the company lacked adequate internal controls to detect and prevent such conduct. For example, InVision's sales department provided only informal training about the FCPA to its employees and foreign agents. Similarly, the company's sales department failed to monitor its employees and foreign agents to ensure that they did not violate the requirements of the FCPA. As InVision's head of sales and a member of the company's board of directors, Pillor aided and abetted InVision's failure to establish adequate internal controls." (Source: US Securities and Exchange Commission Litigation Release No. 19803 / August 15, 2006, SEC v. David M. Pillor, Case No. C-06-4906-WHA (N.D. Cal. filed Aug. 15, 2006), "SEC Settles Charges Against Former InVision Technologies Senior Vice President for Sales and Marketing.") According to the same Litigation Release, "Simultaneous with the filing of the Commission's complaint, Pillor agreed, without admitting or denying the allegations, to pay a $65,000 civil penalty and to entry of a permanent injunction against future violations, in settlement of the matter." (Source: Ibid.)