As part of a settlement with the Department of Justice over alleged violations of the Foreign Corrupt Practices Act (FCPA) (see Pfizer instance, “Foreign Corrupt Practices Act Deferred Prosecution Agreement”), Pfizer and Wyeth LLC (acquired by Pfizer in 2009) paid the Securities and Exchange Commission (SEC) a combined total of $45.2 million in disgorgement of profits and interest. The SEC charged Pfizer and Wyeth with violating the FCPA by making improper payments to government officials in several countries including Bulgaria, China, Croatia, Czech Republic, Indonesia, Italy, Kazakhstan, Pakistan, Russia, Saudi Arabia, and Serbia, and attempting to conceal the improper payments.