Section 6.22 Illegal Payments; Sanctions.
(a) No Target Company or, to the Knowledge of the Company, any of their respective officers, directors, agents or employees (acting in their capacity as such) has, directly or indirectly taken any action which would cause it to be in violation of the Foreign Corrupt Practices Act of 1977, as amended, or any rules or regulations thereunder or any similar anti-corruption or anti-bribery Law applicable to the Target Companies in any jurisdiction other than the United States (collectively, the FCPA) or, in violation of the FCPA since January 1, 2016, directly or indirectly, (i) used any corporate funds for unlawful contributions, gifts, entertainment or other unlawful expenses relating to political activity, (ii) made, offered or authorized any unlawful payment to foreign or domestic government officials or employees, whether directly or indirectly or (iii) made, offered or authorized any unlawful bribe, rebate, payoff, influence payment, kickback or other unlawful payment, whether directly or indirectly.
(b) The operations of each Target Company are, and since January 1, 2016 have been, conducted in compliance with all anti-money laundering laws, rules, regulations and guidelines (collectively Money Laundering Laws) and no investigation, action, suit or proceeding before any Governmental Authority involving any Target Company with respect to Money Laundering Laws is pending, or to the Knowledge of the Company, is threatened.
(c) Sanctions. The Target Companies are, and since January 1, 2016, have been in compliance in all material respects with, and has not been penalized for, or under investigation by a Governmental Authority with respect to, and, to the Knowledge of the Company, has not been threatened to be charged with or given notice of any violation of, any relevant applicable Laws related to export control or laws related to sanctions administered by the U.S. Department of Treasurys Office of Foreign Assets Control, the U.S. Department of State, the United Nations Security Council, the European Union or any other relevant sanctions authority (collectively, Sanctions). Since January 1, 2016, the Target Companies and, to the Knowledge of the Company, their respective officers, directors, agents or employees (acting in their capacity as such) have conducted their businesses in compliance with Sanctions laws.
Section 6.23 Next Twelve Months Revenue. As of the Locked Box Date, the Next Twelve Months Revenue was at least $57,300,000.
Section 6.24 Service Companies Expenses and Costs. Schedule 6.24(a) of the Company Disclosure Letter sets forth the fees, costs and expenses paid by the Target Companies to AP Service Company during calendar years 2016, 2017 and 2018. Schedule 6.24(b) of the Company Disclosure Letter sets forth the fees, costs and expenses paid by the Target Companies to AP Service Company from January 1, 2019 to September 30, 2019.
Section 6.25 Data Protection
(a) To the Knowledge of the Company, none of the Target Companies are in violation of any Data Protection Laws including Regulation (EU) 2016/679 (GDPR) in any material respect; The Data Protection Act 2018; or Directive 2002/58/EC on Privacy and Electronic Communication (as amended) (and any law used to implement this Directive).
(b) None of the Target Companies have received any notice (including any enforcement notice, de-registration notice or transfer prohibition notice), letter, or complaint, from a data protection authority, or any data subject, alleging material non-compliance with the Data Protection Laws.