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Image Sensing Systems reports double declination

Minnesota-based Image Sensing Systems said the DOJ has "closed its inquiry" into potential Foreign Corrupt Practices Act violations and the SEC has also closed its investigation.

The company said last week the DOJ decision not to bring an enforcement action cited its "voluntary disclosure, thorough investigation, cooperation and voluntary enhancements to its compliance program."

ISS said in March 2013 that an investigation by police in Poland had triggered an FCPA and U.K. Bribery Act investigation.

The developer of traffic enforcement solutions said two employees of its Poland unit were charged with criminal violations related to a project in the City of Łodź, Poland.

No charges were filed against the company or its Polish subsidiary, Image Sensing said.

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Here's the full text of Image Sensing's September 8, 2014 release:

Image Sensing Systems, Inc. (NASDAQ: ISNS) today announced that the United States Department of Justice ("DOJ") has closed its inquiry into the Company in connection with the previously disclosed investigation of potential violations of the Foreign Corrupt Practices Act ("FCPA") citing the Company’s voluntary disclosure, thorough investigation, cooperation and voluntary enhancements to its compliance program.

The Securities and Exchange Commission (“SEC”) earlier notified the Company that it had closed its investigation under the FCPA without recommending enforcement action.

Kris Tufto, Image Sensing Systems chief executive officer, commented, "We are very pleased to conclude the DOJ and SEC investigations without further action. From the very beginning, we have voluntarily cooperated with the authorities and have worked diligently to implement measures to enhance our internal controls and compliance efforts. We understand that those efforts have been recognized and that the resolution of the investigation reflects this cooperation."

As previously reported by Image Sensing Systems, it had learned in early 2013 that Polish authorities were conducting an investigation into alleged violations of Polish law by two employees of Image Sensing Systems Europe Limited SP.Z.O.O., its Polish subsidiary, who had been charged with criminal violations of certain laws related to a project in Poland.

A special subcommittee of the audit committee of the board of directors immediately engaged outside counsel to conduct an internal investigation. Image Sensing Systems voluntarily disclosed the matter to the DOJ and the SEC, and it has cooperated fully with those agencies in connection with their review.

Image Sensing Systems was represented in the investigation by the law firms of Greene Espel P.L.L.P. and Dentons Warsaw, with the assistance of FTI Consulting, which provided forensic accounting services.


Richard L. Cassin is the publisher and editor of the FCPA Blog. He can be contacted here.