2015 continued the trend of FCPA enforcement actions brought by the SEC with no parallel DOJ enforcement action. As you might expect, these SEC enforcement actions turned on violations of the FCPA accounting provision, either the books and records or the internal controls provisions.… Continue Reading
Bristol-Myers Squibb said in a securities filing that the DOJ closed its FCPA investigation into the company and won’t bring an enforcement action.
In early October, Bristol-Myers Squibb paid $14.7 million to resolve charges by the SEC that its joint venture in China made cash payments and gave other benefits to health care providers at state-owned and state-controlled hospitals in exchange for prescription sales.… Continue Reading
The Securities and Exchange Commission said Monday that Bristol-Myers Squibb agreed to settle charges that its joint venture in China made cash payments and provided other benefits to health care providers at state-owned and state-controlled hospitals in exchange for prescription sales.… Continue Reading
Infant-formula maker Mead Johnson Nutrition Company disclosed a new FCPA investigation in its latest SEC filing.
It said the SEC had asked for documents about its China unit and “certain expenditures” for product promotions that may have violated the FCPA.… Continue Reading
In its Form 10-K filed this month, pharma Bristol-Myers Squibb said an FCPA investigation started by the SEC seven years ago that focused on operations in Germany has expanded to include other countries.… Continue Reading
Authorities in Guangdong Province are responding with special seriousness to industry-wide anti-corruption regulations issued by the Ministry of Health (MOH) in July 2012.
The debate about medical ghosting has focused on the U.S. market. But could the DOJ and SEC now be looking at the practice overseas, where it might violate the FCPA?
It was just two weeks ago that we were waxing about the quiet times for FCPA watchers, due to the temporary bottleneck in the appointment of corporate monitors. But come to think of it, the Justice Department’s Fraud Section, the group in charge of FCPA enforcement, has a lot on its mind right now.… Continue Reading