Mondelez International — originally Kraft Foods — and its wholly owned subsidiary Cadbury will pay $13 million to settle charges that it violated the Foreign Corrupt Practices Act (FCPA).

The company will neither admit nor deny the charges.

The company was represented by Richard Dean of Baker McKenzie in Washington, D.C.

The Securities and Exchange Commission (SEC) alleged that in early 2010, Cadbury India Limited, a subsidiary of Cadbury, retained an agent to interact with Indian government officials to obtain licenses and approvals for a chocolate factory in Baddi, Himachal Pradesh, India.

The SEC said that Cadbury India’s failure to conduct appropriate due diligence on, and monitor the activities of the agent created the risk that funds paid to the agent could be used for improper or unauthorized purposes.

The SEC alleged that Cadbury India’s books and records, which were consolidated into the books and records of Cadbury, did not accurately and fairly reflect the nature of the services rendered by the agent.

Cadbury did not devise and maintain an adequate system of internal accounting controls sufficient to provide reasonable assurances that access to assets and transactions were executed in accordance with management’s authorization and specifically to detect and prevent payments that may be used for improper or unauthorized purposes.