Israel’s Teva Pharmaceutical said in its most recent SEC filing that affiliates in certain countries under investigation “provided to local authorities inaccurate or altered information relating to marketing or promotional practices.”
Teva said it has now identified compliance issues in Russia, certain Eastern European countries, certain Latin American countries, and other countries where it does business.
The sales practices “could rise to the level of FCPA violations and/or violations of local law,” Teva said.
Teva has kept the SEC and the DOJ aware of the new developments, according to the SEC filing.
“No conclusion can be drawn at this time as to any likely outcomes” about the investigations, Teva said.
The SEC subpoenaed first Teva, one of Israel’s biggest companies, in 2012 because of potential FCPA compliance problems in Latin America. The probe then spread to Russia and other countries.
Teva Pharmaceutical Industries Limited trades on the NYSE under the symbol TEVA.
Here’s the full FCPA disclosure from Teva’s May 1, 2014 Form 6-K (Report of Foreign Private Issuer):
Beginning in 2012, Teva received subpoenas and informal document requests from the Securities and Exchange Commission (“SEC”) and the Department of Justice (“DOJ”) to produce documents with respect to compliance with the U.S. Foreign Corrupt Practices Act (the “FCPA”) in certain countries.
Teva has provided and will continue to provide documents and other information to the SEC and the DOJ, and is cooperating with the government in their investigations of these matters.
Teva is also conducting a voluntary worldwide investigation into certain business practices that may have FCPA implications and has engaged independent counsel to assist in its investigation.
In the course of its investigation, which is continuing, Teva has identified issues in Russia, certain Eastern European countries, certain Latin American countries and other countries where it conducts business that could rise to the level of FCPA violations and/or violations of local law.
In connection with its investigation of these issues, Teva has become aware that Teva affiliates in certain countries under investigation provided to local authorities inaccurate or altered information relating to marketing or promotional practices.
Teva continues to bring these issues to the attention of the SEC and the DOJ.
No conclusion can be drawn at this time as to any likely outcomes in these matters.
Richard L. Cassin is the Publisher and Editor of the FCPA Blog. He can be contacted here.