The SEC further alleged that Allianz violated Section 13(b)(2)(B) of the Exchange Act by failing to devise and maintain a system of internal accounting controls sufficient to provide reasonable assurances that transactions were properly recorded. According to the SEC, Allianz was unable to access Utama's accounting system in Indonesia and, therefore, could not detect the transfer of funds to the special purpose account. Similarly, Allianz did not implement controls over the commission payment request process, which allowed the agent to request and make payments without providing any supporting documentation. 3 In order to settle both of these allegations, Allianz agreed to pay disgorgement of $5.3 million, prejudgment interest of approximately $1.7 million and a civil penalty of $5.3 million.