Microsoft paid more than $16.5 million to settle charges that it violated the Foreign Corrupt Practices Act in connection with its operations in four countries. According to the SEC, Microsoft’s subsidiary in Hungary provided discounts on software licenses to its resellers, distributors, and other third parties and used the discounts to fund improper payments to foreign government officials to secure software license sales. The SEC also found that Microsoft’s subsidiaries in Saudi Arabia and Thailand provided improper travel and gifts to both foreign government officials and employees of non-government customers funded through slush funds maintained by Microsoft’s vendors and resellers. The SEC further found that Microsoft’s subsidiary in Turkey provided an excessive discount to an unauthorized third party in a licensing transaction for which Microsoft’s records did not reflect any services provided.