A charge of that size would be the biggest in Japan for misstating earnings, overtaking the 1.6 billion yen imposed on machinery maker IHI Corp in 2008. The FSA fined Nikko Cordial Corp 500 million yen in 2007 after it inflated profit and later sold 50 billion yen of bonds. The brokerage, the predecessor of SMBC Nikko Securities Inc, said at the time that it was restating earnings because "inappropriate accounting" led to errors. Separate provisions in the Financial Instruments and Exchange Act carry criminal penalties for false financial reporting. People who submit false financial statements may face as long as 10 years in prison or maximum fines of 10 million yen. Companies can be fined as much as 700 million yen. "Criminal charges, civil liability and administrative fines are all possible," said Tatsuo Uemura, who teaches law at Waseda University in Tokyo. "I suspect that what Toshiba did was window dressing, which goes beyond just inadequate accounting."