Stryker | The FCPA Blog

Editors

Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
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

Bill Steinman
Contributing Editor

After Strkyer II, are per diems atop expenses always improper?

Kyden Creekpaum November 6, 2018

A little-noticed nugget in the recent Stryker SEC Order (Stryker II) — in addition to overbilling, kickbacks, and using unvetted intermediaries in India and China — was the allegation that Stryker’s “Kuwait Distributor made over $32,000 in improper ‘per diem’ payments to Kuwaiti [healthcare providers] to attend Stryker events, when Stryker had directly paid the costs for lodging, meals, and local transportation for these individuals.” … Continue Reading

Stryker hit with second FCPA enforcement action

Richard L. Cassin September 28, 2018

Medical device maker Stryker Corp. agreed Friday to pay the SEC a $7.8 million penalty to resolve FCPA books and records and internal accounting controls offenses in India, China, and Kuwait.… Continue Reading

How do pharmas pay bribes? The SEC counts the ways

Richard L. Cassin March 3, 2015

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

Special report: Has the FBI disbanded its FCPA Unit?

Julie DiMauro October 31, 2013

The FCPA Blog posed this question to the DOJ and FBI’s public affairs’ offices Wednesday: Has the FCPA Unit at the FBI been disbanded? In response, Christopher Allen in the FBI’s Public Affairs Office said: “The FBI’s investigations are managed through the International Corruption Unit, and that unit is absolutely not being disbanded.”… Continue Reading

Stryker pays $13.2 million in SEC settlement

Richard L. Cassin October 24, 2013

The SEC said Thursday that medical device and equipment maker Stryker Corporation will pay $13.2 million to resolve FCPA violations.

Michigan-based Stryker bribed doctors and administrators at government controlled hospitals in Argentina, Greece, Mexico, Poland, and Romania, the SEC said.… Continue Reading

New disclosure from Stryker

The FCPA Blog July 24, 2013

Here’s the FCPA disclosure from medical device-maker Stryker Corporation’s Form 10-Q filed with the SEC on July 23:

In 2010 we received a subpoena from the United States Department of Justice (DOJ) related to the sales and marketing of the OtisKnee device.

Medtronic wins double declination

Richard L. Cassin June 27, 2013

Minnesota-based Medtronic Inc. won a double declination following an FCPA probe that lasted more than five years. The medical device maker said it received word in June from the DOJ and SEC that they won’t pursue enforcement actions.… Continue Reading

Stryker’s latest FCPA disclosure

The FCPA Blog October 24, 2012

From the members area of the FCPA Blog, here’s Stryker’s latest FCPA disclosure in its SEC filing this week:

Stryker Corp.

Filing Date Oct/22/2012

Investigating Entity Securities and Exchange Commission

Excerpt In 2010 we received a subpoena from the DOJ related to sales, marketing and regulatory matters related to the Stryker PainPump.… Continue Reading

Stryker’s Latest Disclosure

The FCPA Blog July 26, 2012

Here’s Michigan-based Stryker Corporation’s full FCPA disclosure from its Form 10-Q filed with the SEC on July 24. The company makes medical devices used for implants and reconstructive procedures.

In 2007 we disclosed that the United States Securities and Exchange Commission (SEC) made an inquiry of us regarding possible violations of the Foreign Corrupt Practices Act (FCPA) in connection with the sale of medical devices in certain foreign countries.