Furthermore, the SEC found that Bahn falsely represented that there was a buyer committed to acquiring the building in the first place. In doing so, Bahn caused an accounting calamity, wherein Colliers improperly recorded real estate sales commission revenue that it never received.
“Although the fact pattern here is atypical, the underlying violations are straightforward,” Charles Cain, chief of the SEC Enforcement Division’s FCPA Unit said. “Bahn engaged in an egregious bribe scheme that involved a web of lies and false documents as he attempted to bribe a foreign official in order to make a sale.”
In the end, the SEC’s order found that Bahn violated the FCPA’s antibribery provisions, caused violations of the act’s books and records provisions, intentionally circumvented Colliers International Group’s internal accounting controls and falsified its corporate books and records.
Bahn has agreed to pay $225,000 in disgorgement. The SEC deemed that the forfeiture and restitution ordered at his Thursday sentencing in a related criminal proceeding satisfied the disgorgement.