Former Nissan Motor Co. executive Greg Kelly was released from jail in Japan Tuesday after a Tokyo court rejected prosecutors’ request to continue to detain him.

The Tokyo District Court granted his release after setting bail at $636,000.

Kelly had been detained for 37 days after being arrested and charged with underreporting the pay of his boss, ousted Nissan Chairman Carlos Ghosn, by $44 million.

Ghosn was also arrested along with Kelly on November 19 on suspicion of conspiring to understate Ghosn’s pay. Ghosn remains in custody.

The charge is part of a wider effort by Japanese prosecutors and the auto company to show that Ghosn leveraged his position for personal gain.

The court set restrictions on Kelly’s release. Kelly is prohibited from traveling outside Japan without the court’s permission and from meeting with people linked to the case against him.

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