SEC v. Sam P. Wallace Co., Inc., Robert D. Buckner, and Alfonso A. Rodriguez (D.D.C. 1983)

• Case Name
• SEC v. Sam P. Wallace Co., Inc., Robert D. Buckner, and Alfonso A. Rodriguez (D.D.C. 1983)

• Date Filed
• 02/23/1983

• Enforcement Agency
• SEC

• Countries
• Trinidad & Tobago

• Foreign Official
• Unnamed foreign government officials.

• Date of Conduct
• 1980 to 1981

• Nature of Business
• Sam P. Wallace Co. (“Wallace Co.”) is a Texas corporation and an issuer engaged in mechanical, electrical, and civil construction domestically and internationally.   Its common stock is registered with the SEC pursuant to Section 12(b) of the Exchange Act.  Robert D. Buckner was Wallace Co.’s board chairman, chief executive officer, and director during the relevant time.  Alfonso A. Rodriguez was the executive vice president of Wallace Co., as well as the regional manager of two Wallace Co. subsidiaries.  Later, Rodriguez became a director of Wallace Co.  

• Influence to be Obtained
• According to the SEC, Wallace Co. made $1.391 million in improper payments to foreign officials to obtain and retain contracts with the foreign government.   

• Enforcement
• Wallace Co., Buckner, and Rodriguez consented to the entry of a permanent injunction prohibiting future violations of the FCPA.  In addition, Wallace Co. agreed to the establishment of an independent committee of the board of directors to conduct an internal investigation and report to the SEC.
  
  In a related action, Wallace Co. pled guilty to violations of the books-and-records provision of the FCPA and the Currency and Foreign Transactions Reporting Act, and it was required to pay a criminal penalty of $530,000.  Rodriguez also pled guilty to one count of violating the FCPA’s anti-bribery provision and was sentenced to two years of probation and required to pay a fine of $10,000. 

• Amount of the Value
• $1.391 million.

• Amount of Business Related to Payment
• Not Stated

• Intermediary
• None

• Citizenship of Parent Entity
• United States

• Compliance Monitor
• Yes

• Reporting Requirements
• No

• Case is Pending?
• No

• Total Combined Monetary Sanction
• $ 530,000

Sam P. Wallace Co., Inc.

• Citation
• SEC v. Sam P. Wallace Co., et al., No. 81-cv-1915 (D.D.C. 1983).

• Date Filed
• 02/23/1983

• Filed Under Seal
• No

• FCPA Statutory Provision
• • Anti-Bribery

• Other Statutory Provision
• Securities Fraud (Exchange Act Section 10(b)); False Statements to Regulators (Exchange Act Section 13(a)); False Proxy Statement (Exchange Act Section 14(a)).

• Disposition
• Complaint and Consent Order

• Defendant Jurisdictional Basis
• Issuer

• Defendant's Citizenship
• United States

Robert D. Buckner

• Citation
• SEC v. Sam P. Wallace Co., et al., No. 81-cv-1915 (D.D.C. 1983).

• Date Filed
• 02/23/1983

• Filed Under Seal
• No

• FCPA Statutory Provision
• • Anti-Bribery

• Other Statutory Provision
• Securities Fraud (Exchange Act Section 10(b)); False Statements to Regulators (Exchange Act Section 13(a)); False Proxy Statement (Exchange Act Section 14(a)).

• Disposition
• Complaint and Consent Order

• Defendant Jurisdictional Basis
• Issuer

• Defendant's Citizenship
• United States

Alfonso A. Rodriguez 

• Citation
• SEC v. Sam P. Wallace Co., et al., No. 81-cv-1915 (D.D.C. 1983).

• Date Filed
• 02/23/1983

• Filed Under Seal
• No

• FCPA Statutory Provision
• • Anti-Bribery

• Other Statutory Provision
• Securities Fraud (Exchange Act Section 10(b)); False Statements to Regulators (Exchange Act Section 13(a)); False Proxy Statement (Exchange Act Section 14(a)).

• Disposition
• Complaint and Consent Order

• Defendant Jurisdictional Basis
• Issuer

• Defendant's Citizenship
• United States