SEC v. Chandramowli Srinivasan (D.D.C. 2007)
Case Details
- Case Name
- SEC v. Chandramowli Srinivasan (D.D.C. 2007)
- Foreign Official
- Senior employees of two Indian energy companies that were partly government owned.
- Date of Conduct
-
2001 to 2003
- Nature of Business
- Electronic Data Systems Corporation (“Electronic Data”), a U.S. corporation, provides management consulting services. Chandramowli Srinivasan was the founder and president of A.T. Kearney Ltd. – India (“Kearney Ltd.”), Electronic Data’s India based subsidiary. During the relevant period of time, Electronic Data’s shares were registered with the SEC pursuant to Section 12(b) of the Exchange Act.
- Influence to be Obtained
- Srinivasan allegedly made improper payments to prevent Kearney Ltd.’s two primary customers from canceling their existing contracts with Kearney Ltd. and to award additional contracts to Kearney Ltd. These payments were allegedly partially effected by means of phony invoices prepared by Kearney Ltd.’s outside accountant.
- Enforcement
- On September 25, 2007, the SEC filed a settled civil action against Srinivasan, alleging violations of the FCPA’s anti bribery and internal controls provisions. Without admitting or denying the allegations, Srinivasan consented to the entry of final judgment against him enjoining future violations, and agreed to pay a penalty of $70,000. The SEC also brought a related administrative action against Electronic Data under the ‘34 Act on September 25, 2007, in which Electronic Data consented to a cease and desist order and agreed to pay $490,902 in disgorgement.
- Amount of the Value
- Over $720,000.
- Amount of Business Related to Payment
- Over $7.5 million.
- Reporting Requirements
- No
Defendants
Chandramowli Srinivasan
- Citation
- SEC v. Srinivasan, 07-cv-1699 (D.D.C. 2007).
- Other Statutory Provision
- None
- Disposition
- Complaint and Consent Order
- Defendant Jurisdictional Basis
- Agent of Issuer
