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IBM's FCPA Enforcement Action Settlement

On March 18, 2011, Cravath client IBM announced that it has entered into an agreement to settle allegations made by the Securities and Exchange Commission (the “SEC”), that it violated the books and records and internal control provisions of the Foreign Corrupt Practices Act. Without admitting or denying the SEC’s allegations, IBM agreed to pay $10 million.

The Cravath team included partners Evan R. Chesler and Peter T. Barbur and associates Benjamin Gruenstein, Karl C. Huth, Katherine Deringer Janson and John E. Roberts.