he SEC’s inquiry and conducted a thorough internal investigation to determine the scope of the improper payments and other misconduct involved.”). 3% SEC Rules of Practice, 17 C.ER. § 201.102(e). 385 Deferred Pros. Agreement, In the Matter of Tenaris, S.A. (May 17, 2011), available at http ://www.sec.gov/news/press/2011