News & Analysis as of

Enforcement Actions Bribery Pharmaceutical Industry

Greenbaum, Rowe, Smith & Davis LLP

First Circuit Decision Regarding Anti-Kickback Statute Standard Widens Circuit Split and Creates Potential for Supreme Court...

The U.S. Court of Appeals for the First Circuit, in United States v. Regeneron, has joined the Sixth and Eighth Circuits in adopting the “but-for” standard to find that a violation of the Anti-Kickback Statute (AKS) triggers...more

Shumaker, Loop & Kendrick, LLP

Client Alert: Have You Looked at Who is Coming to Dinner and How It Impacts Your Compliance?

Several States' Attorneys General reported resolving a case alleging that Gilead Sciences ran an illegal kickback scheme to promote the use of its HIV medications. The government alleged that Gilead utilized various methods,...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for June 2025

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

White & Case LLP

China Released First-of-Its-Kind Compliance Guidelines for Healthcare Companies to Prevent Commercial Bribery Risks

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On January 10, 2025, China's State Administration for Market Regulation ("SAMR"), the top anti-graft regulator, put into effect its first-of-its-kind Compliance Guidelines for Healthcare Companies to Prevent Commercial...more

DLA Piper

The Future of "Counterparty Bribery" Offenses Under China's Anti-Unfair Competition Law

DLA Piper on

Pending proposals to amend China's Anti-Unfair Competition Law (AUCL) may further blur the line between antitrust and anti-corruption offenses under China's enigmatic "counterparty bribery" rules. The AUCL, first enacted in...more

Hogan Lovells

China’s first compliance guidelines to prevent corruption risks in the life sciences industry

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On January 14, 2025, China issued the final version of its compliance guidelines for health care companies to prevent commercial bribery risks (“Guidelines”), which took effect immediately. The Guidelines are applicable to...more

Jones Day

China Finalizes Its First Anti-Corruption Guidelines for the Health Care and Life Sciences Industry

Jones Day on

On January 14, 2025, China's State Administration for Market Regulation ("SAMR"), the primary regulatory agency in China for overseeing market supervision, issued its Compliance Guidelines for Health Care Companies to Prevent...more

The Volkov Law Group

The Continuing Plague of Healthcare Fraud

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Healthcare fraud is an ever-growing constant in our economy.  It is a battle that presents new and exponential challenges.  The U.S. Department of Justice, the HHS-Office of Inspector general and State Attorneys’ General all...more

Rivkin Radler LLP

NYC Pharmacy Owner Charged With Healthcare Fraud

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The owner of Brooklyn Chemists in Gravesend, Brooklyn and Lucky Care Pharmacy in Flushing, Queens was recently indicted on charges of conspiracy to commit health care fraud, conspiracy to defraud the United States by paying...more

Thomas Fox - Compliance Evangelist

Alexion Pharmaceuticals FCPA Enforcement Action: Part 2 – Data Analytics

The same day that the 2020 Resource Guide was released, the Securities and Exchange Commission (SEC) announced it had settled a Foreign Corrupt Practices Act (FCPA) enforcement action involving Alexion Pharmaceuticals Inc....more

Thomas Fox - Compliance Evangelist

Alexion Pharmaceuticals FCPA Enforcement Action: Part 1 – The Bribery Schemes

The same day that the 2020 Resource Guide was released the Securities and Exchange Commission (SEC) announced it had settled a Foreign Corrupt Practices Act (FCPA) enforcement action involving Alexion Pharmaceuticals Inc....more

The Volkov Law Group

Alexion FCPA Violations: Lessons Learned (Part II of II)

The Volkov Law Group on

The Alexion Pharmaceutical SEC FCPA enforcement action represents another in the long line of enforcement actions against drug and device companies.  The drug and device industries have been – and will continue to be — easy...more

The Volkov Law Group

Alexion Pays SEC $21 Million for FCPA Violations (Part I of II)

The Volkov Law Group on

Notwithstanding the pandemic and remote working arrangements, the Securities and Exchange Commission is continuing to bring FCPA enforcement actions....more

Foley Hoag LLP - White Collar Law &...

White Collar Year in Preview: Healthcare Fraud Trends in 2020

Editors’ Note: This is the second in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed SEC enforcement in 2020. Up next: a look at...more

The Volkov Law Group

2019 FCPA Enforcement Highlights (Part II of III)

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In a record year, there are bound to be numerous interesting enforcement actions and principles.  I picked out a few to highlight....more

Thomas Fox - Compliance Evangelist

Bribery Schemes from 2019 FCPA Enforcement Actions

In today’s blog post, I want to look at some of the more unusual bribery schemes from Foreign Corrupt Practices Act (FCPA) enforcement actions in 2019. Some of these schemes were not unusual but they were accomplished with...more

The Volkov Law Group

FCPA 2019: A Record Year in Enforcement and Compliance (Part I of III)

The Volkov Law Group on

Happy New Year!! In the FCPA arena, 2019 was a record year – in enforcement and compliance. Many continuing trends are becoming more than trends – meaning they are turning into established practices....more

Thomas Fox - Compliance Evangelist

Top Five Department of Justice FCPA Enforcement Actions in 2019

Welcome to the 2020’s. The past decade helped shape both Foreign Corrupt Practices Act (FCPA) enforcement and corporate compliance programs. 2019 FCPA enforcements bore out many of the developments from the preceding years of...more

Robins Kaplan LLP

Financial Daily Dose 11.25.2019 | Top Story: London denies Uber license, sowing chaos for its 45k drivers there

Robins Kaplan LLP on

The City of London has denied Uber’s request to extend its license in the city over concerns for rider safety. The decision puts Uber’s 45,000 drivers there in limbo, though they’ll be able to continue operating while the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Cross-Border Investigations Update - September 2019

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including a review of the first year of GDPR enforcement, analysis of...more

Thomas Fox - Compliance Evangelist

Corruption in China: Part 2 – The Bribery Schemes

After a sidetrack into the ethical train wreck detailed by the SEC Cease and Desist Order re: KPMG yesterday, I am returning to the blog post series I am running based upon the New York Times (NYT) reporting by Alexandra...more

Hogan Lovells

U.S. and Brazilian Authorities Reportedly Cooperating in Investigation of Alleged Bribery and Price Fixing Related to Medical...

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In a May 17, 2019 press report that has been widely distributed in Brazil and the United States, Brazilian Federal Prosecutor Marisa Ferrari confirmed that the U.S. Federal Bureau of Investigation (FBI), the U.S. Department...more

Thomas Fox - Compliance Evangelist

Fresenius FCPA Enforcement Action: Part VI – FCPA Enforcement Going Forward

We are at the end of my exploration of the long-awaited Fresenius Medical Care AG & Co. KGaA (FMC) Foreign Corrupt Practices Act (FCPA) enforcement action. ...more

Thomas Fox - Compliance Evangelist

Fresenius FCPA Enforcement Action: Part V – Lessons Learned on Investigative Steps and Remedial Actions

We continue this multipart exploration of the recent announcement of the Fresenius Medical Care AG & Co. KGaA (FMC) Foreign Corrupt Practices Act (FCPA) enforcement action....more

Thomas Fox - Compliance Evangelist

Fresenius FCPA Enforcement Action: Part IV – Lessons Learned on the Bribery Schemes

We continue this multipart exploration of the recent announcement of the Fresenius Medical Care AG & Co. KGaA (FMC) Foreign Corrupt Practices Act (FCPA) enforcement action....more

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