The company entered into a separation agreement with the whistleblowing employee that included non-disclosure and a "substantial financial penalty" for violating the agreement, according to the SEC. Despite repeated complaints from employees, AB InBev, now based in Leuven, Belgium, had inadequate internal accounting controls to detect and prevent the payments, the SEC said. "Anheuser-Busch InBev recorded improper payments by its sales promoters in India as legitimate expenses in its financial accounting, and then exacerbated the problem by including language in a separation agreement that chilled an employee from communicating with the SEC," said Kara Brockmeyer, chief of the SEC Enforcement Division's FCPA Unit.