A number of Daimler's former senior executives, who operated ina decentralized corporate structure, per-although Germany outlawed bribery in mitted or were directly involved in the 1999 when it ratified the OECD Anti- Company's bribery practices, includ- Bribery Convention, Daimler had become ing the head of its overseas sales an SEC registrant in 1993 and became sub- department, who reported directly to ject to the FCPA at that time.