ELBIT IMAGING LTD.

INDUSTRY

Real Estate

CORPORATE HEADQUARTERS

Petach Tikva, Israel

SUMMARY OF ALLEGATIONS

Nationality of Foreign Officials: Romania

Summary of Allegations:

Elbit identified and disclosed possible U.S. Foreign Corrupt Practices Act ("FCPA") violations, including the books and records provisions, over agreements that were executed in the past in connection with the Casa Radio Project in Bucharest, Romania and the sale of a large portfolio of real estate assets in the U.S. 

Elbit and its subsidiary, Plaza Centers NV, paid millions in service fees to third party offshore consultants and sales agents without knowledge of whether the services were actually provided. 

 


Approximate Alleged Payments to Foreign Officials: Millions

Business Advantage Allegedly Obtained: Unspecified

ENFORCEMENT RESULTS

Agencies: Internal Investigation
Results:
Year Resolved: 2018
Compliance Monitor:
Ongoing: No
Details:

In its Audited Consolidated Financial Statement as of 31 December 2015 filed with the U.S. Securities and Exchange Commission ("SEC"), Elbit disclosed that its audit committee has decided to appoint a special committee to examine potential violation of the FCPA, including any internal control and reporting issues.



Agencies: United States: Securities and Exchange Commission
Results: Administrative Order, Cease-and-Desist Order, Civil Penalty
Year Resolved: 2018
Compliance Monitor:
Ongoing: No
Details:

April 2016 - In its audited Consolidated Financial Statement as of 31 December 2015 filed with the U.S. Securities and Exchange Commission ("SEC"), Elbit disclosed the SEC's investigation and its intention to fully cooperate in the matter.

09 March 2018 - The SEC issued an administrative order in the Elbit matter, with Elbit's consent, that ordered Elbit to cease and desist from committing any further / future violations of Sections 13(b)(2)(A)  Sections 13(b)(2)(B) of the Exchange Act and to pay the $500,000 civil penalty that Elbit offered as a settlement. The SEC did not admit or deny the findings of the case.

The SEC's willingness to accept Elbit's settlement offer was based on its self-reporting, prompt remedial efforts, cooperation with the SEC's investigation, and the fact that Elbit is in the process of winding down and isn't currently developing new business.

 



ENTITIES/INDIVIDUALS INVOLVED

DETAILS OF HOW CONDUCT WAS DISCOVERED

Discovery Method: Unspecified
Details:
Country: Romania

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