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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Double declination for Baxter

Big pharma Baxter International said Friday the DOJ and SEC have closed their FCPA investigations and the agencies won’t take further action.

The declinations were first reported by Rachel Louise Ensign at the Wall Street Journal.

Baxter disclosed in 2010 that it received inquiries from the SEC and DOJ requesting information about business activities in “a number of countries” as part of an industry-wide Foreign Corrupt Practices Act investigation.

In August last year, Baxter told the Wall Street Journal that following whistleblower complaints, it investigated allegations and found improper expense payments by a China joint venture.

Baxter said it received the internal complaints in July 2012 and conducted an investigation.

It “disciplined the venture’s leadership, conducted new training and enhanced its controls and monitoring of interactions with Chinese health-care professionals, according to people familiar with the matter,” the WSJ said.

Baxter International Inc.’s Form 10-K filed with the SEC on February 21, 2014 said:

The company was the recipient of an inquiry from the U.S. Department of Justice (DOJ) and the SEC that was part of a broader review of industry practices for compliance with the U.S. Foreign Corrupt Practices Act. In January 2014, the company was notified by both the DOJ and the SEC that their respective investigations were closed as to Baxter without any further action taken by either agency.


Richard L. Cassin is the publisher and editor of the FCPA Blog. He can be contacted here.

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1 Comment

  1. Richard- forgive me if these questions sound naive. Don't these companies have written codes of conduct that prohibit this sort of behavior? If not, why not? If so, why aren't they enforced?

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