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Medtronic wins double declination

Minnesota-based Medtronic Inc. won a double declination following an FCPA probe that lasted more than five years. The medical device maker said it received word in June from the DOJ and SEC that they won’t pursue enforcement actions.

Medtronic was one of the medical device companies caught in an industry sweep of their overseas marketing practices that began in 2007.

Since then, several have settled FCPA enforcement actions.

Johnson & Johnson paid $70 million in 2011. And last year Smith & Nephew paid $21 million and Bioment almost $23 million.

Earlier this year, however, Zimmer also won a double declination from the DOJ and SEC.

In 2007, Johnson & Johnson and its DePuy subsidiary, along with Biomet, Zimmer, Smith & Nephew, and Stryker paid $310 million to resolve charges they paid kickbacks to induce U.S. doctors to buy their products.

Within weeks of the domestic settlement, the device makers began disclosing FCPA investigations involving their overseas sales practices.


Medtronic’s full FCPA disclosure from its Form 10-Q filed with the SEC on June 24 said:

On September 25, 2007 and November 16, 2007, the Company received letters from the U.S. Securities and Exchange Commission (SEC) and the U.S. Department of Justice (DOJ), respectively, requesting information relating to any potential violations of the U.S. Foreign Corrupt Practices Act in connection with the sale of medical devices in several non-U.S. countries. A number of competitors have publicly disclosed receiving similar letters. Subsequently, the SEC and DOJ made additional requests for information from the Company. In June 2013, the SEC and the DOJ both informed the Company that they would be closing their investigations without pursuing any enforcement action or charges against the Company.

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