An SEC investigation found that Analogic's Danish subsidiary, BK Medical ApS, engaged in hundreds of sham transactions with distributors that funneled about 20 million to third parties, including individuals in Russia and apparent shell companies in Belize, the British Virgin Islands, Cyprus, and Seychelles. Analogic agreed to pay 7.67 million in disgorgement and 3.8 million in prejudgment interest to settle the SEC?s charges that it failed to keep accurate books and records and maintain adequate internal accounting controls.