UAE Company Resolves Books And Records And Internal Controls Case

With the calendar year end fast approaching, the SEC continues to crank out non-FCPA, FCPA enforcement actions (that is enforcement actions that charge or find violations of the FCPA’s books and records and internal controls provisions) have nothing to do with foreign bribery.
The latest example concerns Brooge Energy Limited – a company with its principal executive office located in Dubai, United Arab Emirates which owns and operates an oil storage facility in the UAE.
In summary fashion, this administrative order finds: