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Harry Cassin
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Andy Spalding
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Richard L. Cassin
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Julie DiMauro
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Thomas Fox
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Marc Alain Bohn
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Bill Waite
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Russell A. Stamets
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Sanofi discloses DOJ declination in FCPA investigation

French pharma Sanofi said Wednesday the DOJ has closed an FCPA investigation that started four years ago.

The company said it heard from the DOJ in February.

But Sanofi said it is still cooperating with the SEC’s “review of the allegations.”

Sanofi disclosed in 2014 an investigation into possible illegal payments in the Middle East and Africa from 2007 to 2012, following allegations from an anonymous whistleblower.

The company self reported the allegations to the DOJ and SEC.

It hired New York law firm Weil Gotshal for the investigation.

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Here’s the full FCPA disclosure from Sanofi’s March 7, 2018 Form 20-F filed with the SEC (courtesy of FCPA Tracker):

Sanofi has been engaged in discussions with the US Department of Justice (“DOJ”) and the US Securities and Exchange Commission regarding allegations that certain subsidiaries outside the United States made improper payments in connection with the sale of pharmaceutical products and whether those payments, if made, fall within the U.S. Foreign Corrupt Practices Act. Sanofi has voluntarily provided information to the DOJ and the SEC and proactively cooperated in both agencies’ review of the allegations. In February 2018, the DOJ notified Sanofi that it had decided to close its inquiry into the allegations. Sanofi is still cooperating with the SEC’s review of the allegations.


Richard L. Cassin is the publisher and editor of the FCPA Blog.

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