English to Italian Law/Patents Law (general)

The company had insufficient internal accounting controls to detect and prevent illicit payments and to provide reasonable assurances that these transactions were recorded accurately in the books and records of these subsidiaries. The payments were made in through a third-party consultant and disguised as honoraria and grants. The case against the company was settled for the disgorgement of illegal profits, interest on the profits and a fine resulting in the US$21.4 million sanction.