Prosecuting Agency:
U.S. Securities and Exchange Commission
Type of Action:
SEC Administrative Proceeding
Docket or Case Number:
3-22237
Name of Prosecuting Attorneys:
Irene Gutierrez, SEC Headquarters
Michelle L. Ramos, SEC Headquarters
Maria Boodoo, SEC Headquarters
Tracy L. Price, SEC Headquarters
US Assisting Agencies: Unknown
Foreign Enforcement Action/Investigation: Unknown
Foreign Assisting Agencies: Unknown
Origin of the Proceeding:
Unknown
Whistleblower:
Unknown
Case Status:
Resolved
Summary
Moog Inc., headquartered in New York, was a worldwide designer and manufacturer of motion controls systems for a broad range of applications in aerospace, defense, industrial and medical markets. The company had sales, engineering, and manufacturing facilities in twenty-six countries. Moog’s shares were registered with the SEC and traded on the New York Stock Exchange under the ticker symbols “MOG.A” and “MOG.B.”
Moog Motion Controls Private Limited (“MMCPL”) was a wholly owned subsidiary of Moog that promoted and solds Moog’s products in India. MMCPL’s financial statements were consolidated with those of Moog.
According to the documents in this case, between 2020 and 2022, MMCPL employees bribed a variety of Indian foreign officials to win business for Moog. The payments were made through third party intermediaries to officials with South Central Railway and Hindustan Aeronautics Limited, both companies wholly owned by the Indian government, as well as Research Design and Standards Organization, a research arm of the Indian Ministry of Railways. The improper payments were falsely recorded as legitimate business expenses in Moog’s books and records. In all, Moog made profits from the scheme of approximately $504,926.
In a settled administrative action initiated on October 11, 2024, the SEC ordered Moog to cease and desist violations of the books and records and internal controls provisions of the FCPA. Under the terms of the settlement, Moog agreed to pay disgorgement of $504,926 plus prejudgment interest of $78,889 and a civil monetary penalty in the amount of $1,100,000, for a total payment of $1,683,815. The SEC noted Moog's cooperation and remediation.
It does not appear that Moog ever publicly disclosed in an SEC filing an FCPA-related investigation into the company prior to the enforcement action. However, it does appear from language in the SEC's proceeding that Moog had made disclosures to the DOJ about the misconduct in India.
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