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Fresenius Medical Care Pays Approximately $232 Million To Resolve Its...
German healthcare firm Fresenius Medical Care AG (a company with American Depositary Receipt shares traded on the NYSE) has been under FCPA scrutiny since 2012 (no that is not a typo). Today the DOJ...
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Issues To Consider From The Fresenius Enforcement Action
This previous post went in-depth into the approximate $232 million Fresenius FCPA enforcement action and this post continues the analysis by highlighting additional issues to consider. Timeline As...
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Healthcare Professionals As “Foreign Officials”
It is one of the more dubious FCPA enforcement theories there is. It has never been subjected to judicial scrutiny. It is a relatively new enforcement theory when one considers that the Foreign...
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Stock Option Grants For Doctors Results In FCPA Enforcement Action
[This post is part of a periodic series regarding “old” FCPA enforcement actions] In March 2005, the DOJ announced that Micrus (a medical device company based in California) agreed to non-prosecution...
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Commission Payments To Chinese Lab Personnel And Doctors Leads To Enforcement...
[This post is part of a periodic series regarding “old” FCPA enforcement actions] In 2005, the DOJ and SEC brought a coordinated enforcement action against Diagnostic Products Corp. (DPC – a...
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Novartis Joins The Repeat Offender Club – This Time Paying Approximately $347...
What happens when the Greek, Swiss, and South Korean subsidiaries of a Swiss company engage in improper conduct in Greece, Vietnam and South Korea? Why of course, approximately $345 million flows into...
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Speaker Fees
Numerous Foreign Corrupt Practices Act enforcement actions have involved the enforcement theory that various foreign health care professionals (HCP’s) are “foreign officials” and thus occupy a status...
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Healthcare Professionals As “Foreign Officials”
It is one of the more dubious FCPA enforcement theories there is. It has never been subjected to judicial scrutiny. It is a relatively new enforcement theory when one considers that the Foreign...
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Stericyle Resolves A Net $59 Million FCPA Enforcement Action
Stericycle (an Illinois based medical waste disposal company) has been under FCPA scrutiny since mid-2017 (See here). As highlighted here, approximately two months ago the company disclosed that it had...
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Issues To Consider From The Stericycle Enforcement Action
This previous post highlighted the recent net $59 million Foreign Corrupt Practices Act enforcement action against Stericycle (an Illinois based medical waste disposal company) for conduct in Brazil,...
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