Enforcement Action

 

Docket or Case Number:    08-cv-02167

Court:    District of Columbia

Initiation Date:    12/12/2008  Information

Prosecuting Agency:    US Securities and Exchange Commission

Name of Prosecuting Attorneys:   

  • Cheryl J. Scarboro, SEC Headquarters
  • Reid Anthony Muoio, SEC Headquarters
  • Tracy L. Price, SEC Headquarters
  • Denise Hansberry, SEC Headquarters
  • Robert I. Dodge, SEC Headquarters

Assisting Agencies:    U.S. Department of Justice , Federal Bureau of Investigation , Munich Office of the Prosecutor General , Internal Revenue Service , United Kingdom's Financial Services Authority , U.S. Attorney's Office for District of Columbia , Hong Kong Securities and Futures Commission

Type of Action:    SEC Federal Court Proceeding

Origin of the Proceeding:    Foreign investigation, Voluntary disclosure

Whistleblower:    Unknown

Case Status:    Resolved


Summary

Siemens Aktiengesellschaft ("Siemens") is a German corporation with its executive offices in Munich, Federal Republic of Germany. Siemens is one of the world's largest manufacturers of industrial and consumer products. Siemens builds locomotives, traffic control systems and electrical power plants. The Company also manufactures building control systems, medical equipment and electrical components, and formerly manufactured communications networks. Siemens employs approximately 428,200 people and operates in approximately 190 countries worldwide. Siemens operated through a complex array of business groups and regional companies. The business groups are divisions within Siemens and are not separate legal entities. The regional companies are wholly- or partly-owned subsidiaries of Siemens. The thirteen principal business groups during the Relevant Period were: Communications ("COM"), Siemens Business Services ("SBS"), Automation and Drives ("A&D"), Industrial Solutions and Services ("I&S"), Siemens Building Technologies ("SBT"), Power Generation ("PG"), Power Transmission and Distribution ("PTD"), Transportation Systems ("TS"), Siemens VDO Automotive ("SV"), Medical Solutions ("MED"), Osram Middle East, Siemens Financial Services ("SFS"), and Siemens Real Estate ("SRE"). Starting on March 12, 2001, Siemens' American Depository Shares were registered with the SEC and traded on the New York Stock Exchange.

Between March 12, 2001 and September 30, 2007, Siemens made thousands of separate payments to third parties in ways that obscured the purpose for, and the ultimate recipients of, the money. At least 4,283 of those payments, totaling approximately $1.4 billion, were used to bribe government officials in return for business to Siemens around the world. Among the transactions on which Siemens paid bribes were those to design and build metro transit lines in Venezuela; metro trains and signaling devices in China; power plants in Israel; high voltage transmission lines in China; mobile telephone networks in Bangladesh; telecommunications projects in Nigeria; national identity cards in Argentina; medical devices in Vietnam, China, and Russia; traffic control systems in Russia; refineries in Mexico; and mobile communications networks in Vietnam. Siemens also paid kickbacks to Iraqi ministries in connection with sales of power stations and equipment to Iraq under the United Nations Oil for Food Program. Siemens earned over $1.1 billion in profits on these fourteen categories of transactions that comprised 332 individual projects or individual sales.

On December 12, 2008, the SEC filed a three count Complaint in the District of Columbia against Siemens alleging violations of the anti-bribery, books & records, and internal controls provisions of the FCPA. On the same date, Siemens entered into a Consent Agreement with the SEC. Under the terms of the agreement, Siemens neither admitted nor denied the allegations in the Complaint but agreed to be enjoined from future violations of the FCPA, to hire an independent monitor (as well as counsel for the monitor) to report on the company's anti-corruption compliance policies and procedures, and to disgorge $350 million, which represented profits gained as a result of the conduct alleged in the Complaint.

Country(ies) involved:    Argentina, Bangladesh, China, Iraq, Israel, Mexico, Nigeria, Russia, Venezuela, Vietnam

Sanction to Bribe Ratio:    $350,000,000 / $1,400,000,000 = 25.00 %

Sanction to Revenue Ratio:    N/A

Sanction to Profit Ratio:    $350,000,000 / $1,100,000,000 = 31.82 %

Number of Related Enforcement Actions (Including This Enforcement Action):    8

Country(ies) involved:    Argentina, Bangladesh, China, Iraq, Israel, Mexico, Nigeria, Russia, Venezuela, Vietnam

Total $ Bribery Payments:    $1,400,000,000

Total $ Revenue Generated from Bribery:    N/A

Total $ Profit Earned or Expenses Avoided from Bribery:    $1,100,000,000

Total $ Monetary Sanctions:    $801,858,957

Sanction to Bribe Ratio:    $801,858,957 / $1,400,000,000 = (57.28 %)

Sanction to Revenue Ratio:    N/A

Sanction to Profit Ratio:    $801,858,957 / $1,100,000,000 = (72.90 %)

Name:    Siemens AG

Place of Incorporation:    Germany

HQ Country(ies):    Germany

Entity Type:    Public Company

FCPA Claims:    Anti-Bribery, Primary, Issuer (15 U.S.C. § 78dd-1) ; Books & Records, Primary, Issuer (15 U.S.C. § 78m (b)(2)(A)) ; Internal Controls, Primary, Issuer (15 U.S.C. § 78m(b)(2)(B))

Related Claims:    N/A

Statutory Basis for FCPA Jurisdiction:    Issuer

Period of Bribery:   1998 - 2007

Total Bribery Payments:    $1,400,000,000

Total Revenue Generated from Bribery:    N/A

Total Profit Earned or Expenses Avoided from Bribery:    $1,100,000,000

Country(ies) involved:    Argentina, Bangladesh, China, Iraq, Israel, Mexico, Nigeria, Russia, Venezuela, Vietnam

Officials Potentially Influenced (Name; Title; Organization): 

  • Name N/A, Cabinet ministers; Argentine government
  • Name N/A, Senior official; Petroleos Mexicanos
  • Name N/A, High-ranking member; Venezuelan central government
  • Name N/A, Director of Procurement; Bangladesh Telegraph & Telephone Board ("BTTB")
  • Name N/A, Officials; Argentine government
  • Name N/A, Title N/A, Russian government-owned customers
  • Name N/A, Former defense minister and diplomat; Venezuelan government
  • Name N/A, Government customers; Nigeria Telecommunications Limited
  • Name N/A, Former minister and member of congress; Argentine government
  • Name N/A, Officials; Vietnamese Ministry of Defense
  • Name N/A, Local politician; Venezuelan government
  • Name N/A, Government customers; Nigerian Ministry of Communications
  • Name N/A, Officials; Vietnamese government
  • Name N/A, Officials; Iraqi Ministry of Electricity
  • Name N/A, Officials; Chinese government
  • Name N/A, Vice President; Nigerian government
  • Name N/A, Deputy Director and Head of Radiology; Songyuan City Central Hospital
  • Name N/A, Officials; Iraqi Ministry of Oil
  • Name N/A, Director; Israel Electric Company
  • Name N/A, President; Nigerian government
  • Name N/A, Doctors; Chinese state-owned hospitals
  • Name N/A, Customers; Organization N/A
  • Name N/A, President; Argentine government
  • Name N/A, Technical Consultant; Moscow Project Implementation Unit
  • Name N/A, Prime Minister ; Bangladeshi government
  • Name N/A, Minister; Argentine Ministry of the Interior
  • Name N/A, Senior officials; Moscow Project Implementation Unit
  • Name N/A, Officials; Venezuelan government
  • Name N/A, Minister; Bangladeshi Ministry of Posts & Telecommunications
  • Name N/A, Head; Argentine Immigration Control

Defendant-Related Entities Involved in the Misconduct:    Former Siemens Communications operating group - Division/Branch Office ; Gas Turbine Technologies S.p.A. - Subsidiary ; Molecular Imaging - Subsidiary ; Oncology Care Solutions - Subsidiary ; OOO Siemens - Subsidiary ; Osram Middle East FZE - Subsidiary ; Siemens Industrial Solutions and Services operating group - Division/Branch Office ; Siemens Limited Bangladesh - Subsidiary ; Siemens Limited Nigeria - Subsidiary ; Siemens Limited Vietnam - Subsidiary ; Siemens Medical Solutions operating group - Division/Branch Office ; Siemens Power Generation operating group - Division/Branch Office ; Siemens Power Transmission and Distribution operating group - Division/Branch Office ; Siemens S.A. - Subsidiary ; Siemens S.A. de CV - Subsidiary ; Siemens S.A.S. of France - Subsidiary ; Siemens Sanayi ve Ticaret A.S. of Turkey - Subsidiary ; Siemens Transportation Systems operating group - Division/Branch Office ; Siemens, SLV - Subsidiary

Third-Party Intermediary:   

  • Business consultant , Agent/Consultant/Broker
  • Business consultants , Agent/Consultant/Broker
  • Chinese business consultant , Agent/Consultant/Broker
  • Chinese business consultants , Agent/Consultant/Broker
  • Cypriot business consultant , Agent/Consultant/Broker
  • Dubai business consultants , Agent/Consultant/Broker
  • Four U.S. based entities controlled by a longtime Siemens consultant , Agent/Consultant/Broker
  • Hong Kong based clothing company , Agent/Consultant/Broker
  • Hong Kong business consultant , Agent/Consultant/Broker
  • Local Iraqi agent , Agent/Consultant/Broker
  • Subcontractor A , Contractor/Sub-Contractor
  • Subcontractor B , Contractor/Sub-Contractor
  • Unnamed business consultants , Agent/Consultant/Broker

Type of Bribe:   Money, Workshop Equipment, Jewelry/Various Luxury Items, Travel/Lodging

Cash, Wire or Check:    Wire Transfer, Cash (bills/coins/etc.)

Purpose of Bribe:    Influence the adjudication of disputes, lawsuits, or enforcement actions, Obtain/retain business, Paying previously promised bribes, Prevent/reduce competition

TRANSACTION OVERVIEW
Metro Transit Lines in Venezuela

Period of Bribery:   2001 – 2007

Total Bribery Payments:    $1,670,000

Total Revenue Generated from Bribery:    $642,000,000

Total Profit Earned or Expenses Avoided from Bribery:    N/A

Country(ies) involved:    Venezuela

Officials Potentially Influenced (Name; Title; Organization):  

  • Name N/A, Officials; Venezuelan government;
  • Name N/A, High-ranking member; Venezuelan central government;
  • Name N/A, Former defense minister and diplomat; Venezuelan government;
  • Name N/A, Local politician; Venezuelan government;

Defendant-Related Entities Involved in the Misconduct:    Siemens S.A. - Subsidiary ; Siemens Transportation Systems operating group - Division/Branch Office

Third Party Intermediary:    Cypriot business consultant - Agent/Consultant/Broker
Dubai business consultants - Agent/Consultant/Broker
Four U.S. based entities controlled by a longtime Siemens consultant - Agent/Consultant/Broker

Type of Bribe:   Money, Workshop Equipment

Cash, Wire or Check:    Wire Transfer

Purpose of Bribe:    Obtain/retain business

TRANSACTION OVERVIEW
Metro Trains and Signaling Devices in China

Period of Bribery:   2002 – 2007

Total Bribery Payments:    $22,000,000

Total Revenue Generated from Bribery:    $1,000,000,000

Total Profit Earned or Expenses Avoided from Bribery:    N/A

Country(ies) involved:    China

Officials Potentially Influenced (Name; Title; Organization):  

  • Name N/A, Officials; Chinese government;

Defendant-Related Entities Involved in the Misconduct:    Siemens Transportation Systems operating group - Division/Branch Office

Third Party Intermediary:    Hong Kong business consultant - Agent/Consultant/Broker

Type of Bribe:   Money

Cash, Wire or Check:    N/A

Purpose of Bribe:    Obtain/retain business

TRANSACTION OVERVIEW
Power Plants in Israel

Period of Bribery:   2002 – 2005

Total Bribery Payments:    $20,000,000

Total Revenue Generated from Bribery:    $786,000,000

Total Profit Earned or Expenses Avoided from Bribery:    N/A

Country(ies) involved:    Israel

Officials Potentially Influenced (Name; Title; Organization):  

  • Name N/A, Director; Israel Electric Company;

Defendant-Related Entities Involved in the Misconduct:    N/A

Third Party Intermediary:    Hong Kong based clothing company - Agent/Consultant/Broker

Type of Bribe:   Money

Cash, Wire or Check:    N/A

Purpose of Bribe:    Obtain/retain business

TRANSACTION OVERVIEW
High-Voltage Transmission Lines in China

Period of Bribery:   2002 – 2003

Total Bribery Payments:    $25,000,000

Total Revenue Generated from Bribery:    $838,000,000

Total Profit Earned or Expenses Avoided from Bribery:    N/A

Country(ies) involved:    China

Officials Potentially Influenced (Name; Title; Organization):  

  • Name N/A, Customers; Organization N/A,

Defendant-Related Entities Involved in the Misconduct:    Siemens Power Transmission and Distribution operating group - Division/Branch Office

Third Party Intermediary:    Chinese business consultant - Agent/Consultant/Broker
Dubai business consultants - Agent/Consultant/Broker

Type of Bribe:   Money

Cash, Wire or Check:    N/A

Purpose of Bribe:    Obtain/retain business

TRANSACTION OVERVIEW
Mobile Telephone Services in Bangladesh

Period of Bribery:   2004 – 2006

Total Bribery Payments:    $5,300,000

Total Revenue Generated from Bribery:    $40,900,000

Total Profit Earned or Expenses Avoided from Bribery:    N/A

Country(ies) involved:    Bangladesh

Officials Potentially Influenced (Name; Title; Organization):  

  • Name N/A, Prime Minister ; Bangladeshi government;
  • Name N/A, Minister; Bangladeshi Ministry of Posts & Telecommunications;
  • Name N/A, Director of Procurement; Bangladesh Telegraph & Telephone Board ("BTTB");

Defendant-Related Entities Involved in the Misconduct:    Siemens Limited Bangladesh - Subsidiary

Third Party Intermediary:    Unnamed business consultants - Agent/Consultant/Broker

Type of Bribe:   Money

Cash, Wire or Check:    N/A

Purpose of Bribe:    Obtain/retain business

TRANSACTION OVERVIEW
Four Telecommunications Projects in Nigeria

Period of Bribery:   2001 – 2007

Total Bribery Payments:    $4,500,000

Total Revenue Generated from Bribery:    $130,000,000

Total Profit Earned or Expenses Avoided from Bribery:    N/A

Country(ies) involved:    Nigeria

Officials Potentially Influenced (Name; Title; Organization):  

  • Name N/A, Government customers; Nigeria Telecommunications Limited;
  • Name N/A, Government customers; Nigerian Ministry of Communications;
  • Name N/A, Vice President; Nigerian government;
  • Name N/A, President; Nigerian government;

Defendant-Related Entities Involved in the Misconduct:    Former Siemens Communications operating group - Division/Branch Office ; Siemens Limited Nigeria - Subsidiary

Third Party Intermediary:    N/A

Type of Bribe:   Money, Jewelry/Various Luxury Items

Cash, Wire or Check:    Cash (bills/coins/etc.)

Purpose of Bribe:    Obtain/retain business

TRANSACTION OVERVIEW
Identity Card Project in Argentina

Period of Bribery:   1998 – 2004

Total Bribery Payments:    $40,000,000

Total Revenue Generated from Bribery:    $1,000,000,000

Total Profit Earned or Expenses Avoided from Bribery:    N/A

Country(ies) involved:    Argentina

Officials Potentially Influenced (Name; Title; Organization):  

  • Name N/A, President; Argentine government;
  • Name N/A, Minister; Argentine Ministry of the Interior;
  • Name N/A, Head; Argentine Immigration Control;
  • Name N/A, Cabinet ministers; Argentine government;
  • Name N/A, Officials; Argentine government;
  • Name N/A, Former minister and member of congress; Argentine government;

Defendant-Related Entities Involved in the Misconduct:    Siemens Power Transmission and Distribution operating group - Division/Branch Office ; Siemens S.A. - Subsidiary

Third Party Intermediary:    Unnamed business consultants - Agent/Consultant/Broker

Type of Bribe:   Money

Cash, Wire or Check:    N/A

Purpose of Bribe:    Obtain/retain business, Paying previously promised bribes

TRANSACTION OVERVIEW
Medical Devices in Vietnam

Period of Bribery:   2005 – 2006

Total Bribery Payments:    $383,000

Total Revenue Generated from Bribery:    $6,000,000

Total Profit Earned or Expenses Avoided from Bribery:    N/A

Country(ies) involved:    Vietnam

Officials Potentially Influenced (Name; Title; Organization):  

  • Name N/A, Officials; Vietnamese government;

Defendant-Related Entities Involved in the Misconduct:    Siemens Limited Vietnam - Subsidiary ; Siemens Medical Solutions operating group - Division/Branch Office

Third Party Intermediary:    Hong Kong business consultant - Agent/Consultant/Broker

Type of Bribe:   Money

Cash, Wire or Check:    Cash (bills/coins/etc.)

Purpose of Bribe:    Obtain/retain business

TRANSACTION OVERVIEW
Medical Devices in China

Period of Bribery:   2003 – 2007

Total Bribery Payments:    $14,400,000

Total Revenue Generated from Bribery:    $295,000,000

Total Profit Earned or Expenses Avoided from Bribery:    N/A

Country(ies) involved:    China

Officials Potentially Influenced (Name; Title; Organization):  

  • Name N/A, Deputy Director and Head of Radiology; Songyuan City Central Hospital;
  • Name N/A, Doctors; Chinese state-owned hospitals;
  • Name N/A, Officials; Chinese government;

Defendant-Related Entities Involved in the Misconduct:    Molecular Imaging - Subsidiary ; Oncology Care Solutions - Subsidiary ; Siemens Medical Solutions operating group - Division/Branch Office

Third Party Intermediary:    Chinese business consultants - Agent/Consultant/Broker
Hong Kong business consultant - Agent/Consultant/Broker

Type of Bribe:   Money, Travel/Lodging

Cash, Wire or Check:    N/A

Purpose of Bribe:    Obtain/retain business

TRANSACTION OVERVIEW
Traffic Control System in Russia

Period of Bribery:   2004 – 2006

Total Bribery Payments:    $741,419

Total Revenue Generated from Bribery:    $27,000,000

Total Profit Earned or Expenses Avoided from Bribery:    N/A

Country(ies) involved:    Russia

Officials Potentially Influenced (Name; Title; Organization):  

  • Name N/A, Technical Consultant; Moscow Project Implementation Unit ;
  • Name N/A, Senior officials; Moscow Project Implementation Unit ;

Defendant-Related Entities Involved in the Misconduct:    OOO Siemens - Subsidiary ; Siemens Industrial Solutions and Services operating group - Division/Branch Office

Third Party Intermediary:    Subcontractor A - Contractor/Sub-Contractor
Subcontractor B - Contractor/Sub-Contractor

Type of Bribe:   Money

Cash, Wire or Check:    N/A

Purpose of Bribe:    Obtain/retain business, Prevent/reduce competition

TRANSACTION OVERVIEW
Refinery Modernization Project in Mexico

Period of Bribery:   2004 – 2004

Total Bribery Payments:    $2,600,000

Total Revenue Generated from Bribery:    N/A

Total Profit Earned or Expenses Avoided from Bribery:    N/A

Country(ies) involved:    Mexico

Officials Potentially Influenced (Name; Title; Organization):  

  • Name N/A, Senior official; Petroleos Mexicanos;

Defendant-Related Entities Involved in the Misconduct:    Siemens Power Generation operating group - Division/Branch Office ; Siemens S.A. de CV - Subsidiary

Third Party Intermediary:    Business consultant - Agent/Consultant/Broker

Type of Bribe:   Money

Cash, Wire or Check:    N/A

Purpose of Bribe:    Influence the adjudication of disputes, lawsuits, or enforcement actions

TRANSACTION OVERVIEW
Medical Devices in Russia

Period of Bribery:   2000 – 2007

Total Bribery Payments:    $55,000,000

Total Revenue Generated from Bribery:    N/A

Total Profit Earned or Expenses Avoided from Bribery:    N/A

Country(ies) involved:    Russia

Officials Potentially Influenced (Name; Title; Organization):  

  • Name N/A, Title N/A, Russian government-owned customers;

Defendant-Related Entities Involved in the Misconduct:    Siemens Medical Solutions operating group - Division/Branch Office

Third Party Intermediary:    Business consultants - Agent/Consultant/Broker

Type of Bribe:   Money

Cash, Wire or Check:    N/A

Purpose of Bribe:    Obtain/retain business

TRANSACTION OVERVIEW
GSM Mobile Network Services in Vietnam

Period of Bribery:   2002 – 2002

Total Bribery Payments:    $140,000

Total Revenue Generated from Bribery:    $35,000,000

Total Profit Earned or Expenses Avoided from Bribery:    N/A

Country(ies) involved:    Vietnam

Officials Potentially Influenced (Name; Title; Organization):  

  • Name N/A, Officials; Vietnamese Ministry of Defense;

Defendant-Related Entities Involved in the Misconduct:    Former Siemens Communications operating group - Division/Branch Office ; Siemens, SLV - Subsidiary

Third Party Intermediary:    Business consultant - Agent/Consultant/Broker

Type of Bribe:   Money

Cash, Wire or Check:    N/A

Purpose of Bribe:    Obtain/retain business

TRANSACTION OVERVIEW
U.N. Oil For Food Program

Period of Bribery:   2000 – 2002

Total Bribery Payments:    $1,700,000

Total Revenue Generated from Bribery:    $124,000,000

Total Profit Earned or Expenses Avoided from Bribery:    $38,226,537

Country(ies) involved:    Iraq

Officials Potentially Influenced (Name; Title; Organization):  

  • Name N/A, Officials; Iraqi Ministry of Electricity;
  • Name N/A, Officials; Iraqi Ministry of Oil;

Defendant-Related Entities Involved in the Misconduct:    Gas Turbine Technologies S.p.A. - Subsidiary ; Osram Middle East FZE - Subsidiary ; Siemens S.A.S. of France - Subsidiary ; Siemens Sanayi ve Ticaret A.S. of Turkey - Subsidiary

Third Party Intermediary:    Local Iraqi agent - Agent/Consultant/Broker

Type of Bribe:   Money

Cash, Wire or Check:    Cash (bills/coins/etc.), Wire Transfer

Purpose of Bribe:    Obtain/retain business

Misconduct by Subsidiary?  Yes


Parent(s):   Siemens AG

Subsidiary:  Siemens S.A.S. of France

  • Percentage of Ownership:    100.00 %
  • Direct or Indirect Ownership:    Unknown
  • Parent Had Knowledge of Sub’s Bribery?:    No
  • Subsidiary Expressly Alleged to Be Parent's Agent:    No
  • Parent Liable for Sub Misconduct?:    Yes

Subsidiary:  Siemens Sanayi ve Ticaret A.S. of Turkey

  • Percentage of Ownership:    100.00 %
  • Direct or Indirect Ownership:    Unknown
  • Parent Had Knowledge of Sub’s Bribery?:    No
  • Subsidiary Expressly Alleged to Be Parent's Agent:    No
  • Parent Liable for Sub Misconduct?:    Yes

Subsidiary:  Osram Middle East FZE

  • Percentage of Ownership:    100.00 %
  • Direct or Indirect Ownership:    Unknown
  • Parent Had Knowledge of Sub’s Bribery?:    No
  • Subsidiary Expressly Alleged to Be Parent's Agent:    No
  • Parent Liable for Sub Misconduct?:    Yes

Subsidiary:  Gas Turbine Technologies S.p.A.

  • Percentage of Ownership:    100.00 %
  • Direct or Indirect Ownership:    Unknown
  • Parent Had Knowledge of Sub’s Bribery?:    No
  • Subsidiary Expressly Alleged to Be Parent's Agent:    No
  • Parent Liable for Sub Misconduct?:    Yes

Subsidiary:  Siemens, S.A. (Argentina)

  • Percentage of Ownership:    100.00 %
  • Direct or Indirect Ownership:    Unknown
  • Parent Had Knowledge of Sub’s Bribery?:    No
  • Subsidiary Expressly Alleged to Be Parent's Agent:    No
  • Parent Liable for Sub Misconduct?:    Yes

Subsidiary:  Siemens Bangladesh Limited

  • Percentage of Ownership:    100.00 %
  • Direct or Indirect Ownership:    Unknown
  • Parent Had Knowledge of Sub’s Bribery?:    No
  • Subsidiary Expressly Alleged to Be Parent's Agent:    No
  • Parent Liable for Sub Misconduct?:    Yes

M&A Negotiated or Completed During Misconduct, Investigation, or Resolution?     No

Re: Siemens AG

  • Inadequate internal controls or auditing

Mitigating Factors Referenced by the Government (Company Defendants):

Defendant Self-Report Cooperation Voluntary Remedial Measures Misconduct Limited to Low Level Individuals Other factors
Siemens AG      

Aggravating Factors Referenced by the Government (Company Defendants):

Defendant Insufficient Cooperation Insufficient Remedial Measures
Siemens AG    

Total Monetary Sanctions for the Action:    $350,000,000

Case Status:    Resolved


Disposition:    Consent Agreement

Date of Disposition:    12/12/2008

Siemens AG

—  Total Monetary Sanctions for Defendant:    $350,000,000

—  Compliance Obligation:    Yes

—  Reporting Obligation:    Independent monitor

—  Admission of Guilt/Acceptance of Responsibility:    No

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