Tracy Linkins Price
The deputy chief in the FCPA unit in Washington, DC, Tracy Price has nearly two decades of experience at the SEC, arriving at the agency soon after she received her law degree at Howard University in 1996.
Price served as the second-in-command in the SEC’s UN oil-for-food inquiry in the mid-2000s. With former SEC FCPA Unit chief Cheryl Scarboro, now at Simpson Thacher & Bartlett, Price handled the dozen cases springing from the corrupted UN programme, netting US$150 million in disgorgement and penalties.
Price and Scarboro also worked on German conglomerate Siemens AG’s US$350 million FCPA settlement with the SEC in December 2008, as part of a wider resolution with the Justice Department and German prosecutors.
The commission later brought civil charges against seven former Siemens executives over alleged bribery in Argentina. Two of them – Bernd Regendantz, a former CFO at Siemens Business Services, and Uriel Sharef, a former managing board member at Siemens – have since settled.
Price was a lawyer on the SEC’s 2010 FCPA case against Swiss electrical equipment manufacturer ABB. The company agreed to pay more than US$39.3 million to settle the SEC's charges.* ABB also paid an additional US$17.1 million to resolve the parallel criminal charges with the Justice Department.
Also in 2010, Price worked on the commission's US$91.4 million settlement with the German automaker Daimler and a US$23.4 million resolution with General Electric over bribery under the oil-for-food programme. She also helped conduct an investigation into Panalpina and six other oil services companies, which paid a combined US$80 million in a series of parallel agreements.
In 2011, Price was involved in an investigation into the drugmaker Johnson & Johnson, which settled with the commission for almost US$49 million over bribes paid in Europe and Iraq.
Since then, Price has had a hand in a number of foreign bribery cases, including settlements with medical device manufacturers Smith & Nephew and Biomet, and financial services company Allianz.
In 2016, Price helped to investigate accounting fraud at oil services company Weatherford International, which paid a US$140 million civil penalty to resolve charges it inflated earnings by using deceptive income tax accounting. The enforcement action included settlements with two former senior accounting executives.
Weatherford previously resolved FCPA charges with the SEC and DOJ in 2013. The Justice Department settlement also charged the company with sanctions violations.
Previously an assistant director in the FCPA unit, Price was promoted to deputy chief in December 2017.