In September 2016, in connection with certain of the same core conduct alleged in the Och-Ziff Foreign Corrupt Practices Act enforcement action, the SEC also released an administrative order finding that (see here for the prior post) Daniel Och (CEO and Chairman of Och-Ziff) was a cause of certain of the company’s FCPA books and records violations and that Joel Frank (CFO – pictured) was a cause of certain of the company’s FCPA books and records and internal controls violations.
Without admitting or denying the SEC’s findings, Och agreed to pay approximately $2.2 million and Frank likewise agreed to resolve the action without admitting or denying the SEC’s findings and the SEC stated that and “a penalty will be assessed against him at a future date.”
Oddly, it took approximately 4.5 years, but earlier this week the SEC ordered that Frank pay a $35,000 civil penalty.