On March 1, 2005, Titan settled the enforcement action brought by the U.S. Securities and Exchange Commission for violations under the U.S. Foreign Corrupt Practices Act (the "FCPA") and agreed to pay approximately $15.5 million in disgorgement of monies obtained as the result of FCPA violations and a $13 million civil penalty.

The SEC materials indicate that the $13 million civil penalty will be satisfied by payment of the criminal fine imposed by the DOJ. Titan also agreed to retain an independent consultant to review Titan's FCPA compliance program.