I’m not defending what Novartis did or trying to find an excuse for the company. It violated the FCPA, and (along with a former subsidiary) paid nearly $347 million in penalties and disgorgement to resolve the offenses.… Continue Reading
Most of us, if we have any sense at all, harbor some healthy distrust of the world’s biggest companies. For good reason we fear the concentrated power of giant corporations. What, after all, is one person compared to the overwhelming might of Facebook, Walmart, or Exxon?… Continue Reading
It’s a scenario that FCPA practitioners see all too regularly. A due diligence report regarding an intermediary reveals that it’s organized not in its home jurisdiction, but in Cyprus. Or Guernsey.… Continue Reading
Job Title: Counsel-Litigation and Legal Compliance
Employer: Eli Lilly
Location: Indianapolis, Indiana USA
Lawyer on global Litigation and Legal Compliance team, with focus on international investigations and litigation, global anti-corruption counseling, privileged internal and government investigations, and counseling the Compliance organization. … Continue Reading
During the first calendar quarter, there were two corporate FCPA enforcement actions — both through SEC administrative orders — and one individual resolution.
In a speech Tuesday at CBI’s Annual Pharmaceutical Compliance Congress in Washington D.C., the head of the SEC’s enforcement division, Andrew Ceresney, left, talked about the most common ways pharmas violate the FCPA.… Continue Reading
Big pharma Eli Lilly said in an SEC filing Thursday that the DOJ has closed its FCPA investigation of the company.
French pharma Sanofi is investigating possible illegal payments in the Middle East and Africa from 2007 to 2012 following allegations from an anonymous whistleblower.
Sanofi said Monday it has self reported the allegations to the U.S.… Continue Reading
Big-pharma Merck said an SEC filing Thursday that the DOJ has closed its FCPA investigation of the company.
Merck first disclosed in 2010 that it received letters from the DOJ and SEC asking for FCPA-related information about its activities in a number of countries.… Continue Reading
The U.S. Securities and Exchange Commission (SEC) published its 2013 Agency Financial Report this week to detail its results for the President, Congress and public.
By the end of the 2013 fiscal year, the SEC had obtained total penalties and disgorgements of $3.4 billion, an increase from the $3.1 billion awarded the year before, it said in the report.… Continue Reading
At the beginning of this year, China’s president Xi Jinping promised to fight both “tigers” and “flies” — high-ranking and low-ranking corrupt officials — in his crackdown on corruption. Since then, the anti-graft campaign has led to the conviction of Bo Xilai and to the front-page investigations of foreign companies in the pharmaceutical and oil and gas sectors, among others.… Continue Reading
A police investigation in China has found that drugmaker GlaxoSmithKline’s alleged bribery of doctors ‘was coordinated by the British company and was not the work of individual employees,’ according to a report Tuesday by Reuters.… Continue Reading