Popular, Bribery, Pharmaceutical Industry

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

Greenbaum, Rowe, Smith & Davis LLP on 7/29/2025

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

Top 10 International Anti-Corruption Developments for June 2025

Morrison & Foerster LLP on 7/16/2025

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

Securities Class Action Against Swiss-Based Company Dismissed On Forum Non Conveniens Grounds

Goodwin on 8/25/2020

Securities Class Action Against Swiss-Based Company Dismissed On Forum Non Conveniens Grounds; Second Circuit Finds Strong Inference of “Conscious Recklessness” In Allegations And Reverses Dismissal of Securities Suit Against...more

Top 10 International Anti-Corruption Developments For July 2020

Morrison & Foerster LLP on 8/13/2020

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

US Department of Justice charges co-owners of pharmaceutical company for fraud

Health Care Compliance Association (HCCA) on 8/1/2020

Compliance Today (August 2020) - The Department of Justice’s Criminal Fraud division indicted six Texas-based owners and marketers for a scheme to defraud TRICARE and the U.S. Department of Labor, resulting in more than $14...more

Novartis’ Simultaneous Settlements Break Records

Akerman LLP - Health Law Rx on 7/22/2020

Novartis Pharmaceuticals Corporation (Novartis) has started July with significant settlements, putting two different fraud and abuse matters behind them. In what has been identified as the largest settlement of an...more

Novartis US Corruption Settlements: Part 1 – Introduction

Thomas Fox - Compliance Evangelist on 7/20/2020

I have written extensively about the Novartis International AG (Novartis) Foreign Corrupt Practices Act (FCPA) settlement, which was announced in late June. However, the enforcement action paled next to the Stipulation and...more

Alexion Pharmaceuticals FCPA Enforcement Action: Part 2 – Data Analytics

Thomas Fox - Compliance Evangelist on 7/17/2020

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

Top 10 International Anti-Corruption Developments For June 2020

Morrison & Foerster LLP on 7/17/2020

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

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

Thomas Fox - Compliance Evangelist on 7/16/2020

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

Novartis’ And Alcon’s $345 Million FCPA Case Signals Increased Scrutiny Of Gifts And Entertainment And New Focus On Scientific...

Vinson & Elkins LLP on 7/16/2020

On June 25, 2020, Novartis AG, a Swiss multinational pharmaceutical company, and two subsidiaries reached a combined $345 million resolution with the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange...more

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

The Volkov Law Group on 7/10/2020

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

Novartis FCPA Enforcement Action: Data Analytics and Lessons Learned

Thomas Fox - Compliance Evangelist on 7/2/2020

This blog post will close my review of the Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss pharmaceutical company Novartis AG, its Greek subsidiary Novartis Hellas S.A.C.I. (Novartis Greece) and...more

Novartis FCPA Enforcement Action: Fines, Penalties and the Cost of Recidivism

Thomas Fox - Compliance Evangelist on 7/1/2020

This week I am reviewing the Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss pharmaceutical company Novartis AG, its Greek subsidiary Novartis Hellas S.A.C.I. (Novartis Greece) and Alcon Pte Ltd.,...more

Novartis and Alcon FCPA Enforcement Action: Lessons Learned (Part III of III)

The Volkov Law Group on 7/1/2020

At the outset, Novartis is “lucky” – the settlement is relatively positive, despite its 2016 SEC enforcement action in China. Given Novartis weak culture of compliance (if anything, a better description may be a culture of...more

Novartis FCPA Enforcement Action: Internal Controls

Thomas Fox - Compliance Evangelist on 6/30/2020

This week I am reviewing the Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss pharmaceutical company Novartis AG, its Greek subsidiary Novartis Hellas S.A.C.I. (Novartis Greece) and Alcon Pte Ltd.,...more

Novartis and Alcon: A Review of Bribery and Accounting Violations (Part II of III)

The Volkov Law Group on 6/30/2020

Novartis and Alcon engaged in separate but significant bribery schemes. Considering the fact that Novartis had a similar violation in 2016 in China involving much of the same conduct, Novartis’ conduct reflects a weak...more

Novartis FCPA Enforcement Action: The Bribery Schemes

Thomas Fox - Compliance Evangelist on 6/29/2020

This week I am reviewing the Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss pharmaceutical company Novartis AG, its Greek subsidiary Novartis Hellas S.A.C.I. (Novartis Greece) and Alcon Pte Ltd.,...more

Novartis FCPA Enforcement Action: Introduction

Thomas Fox - Compliance Evangelist on 6/26/2020

Proving that the era of large Foreign Corrupt Practices Act (FCPA) enforcement action is not over, the Swiss pharmaceutical company Novartis AG, its Greek subsidiary Novartis Hellas S.A.C.I. (Novartis Greece) and Alcon Pte...more

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

The Volkov Law Group on 1/7/2020

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

Top Five Department of Justice FCPA Enforcement Actions in 2019

Thomas Fox - Compliance Evangelist on 1/2/2020

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

Walking the Line Between Marketing and Malfeasance

Butler Snow LLP on 10/7/2019

Opioid manufacturers, distributors, pharmacies and prescribers are facing a deluge of lawsuits that involve criminal and civil claims in both federal and state courts. On May 2, 2019, a federal jury in Boston, Massachusetts,...more

Cross-Border Investigations Update - September 2019

Skadden, Arps, Slate, Meagher & Flom LLP on 10/3/2019

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

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

Hogan Lovells on 5/21/2019

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

Fresenius Medical’s Bribery Conduct Precludes Declination (Part II of III)

The Volkov Law Group on 4/3/2019

Fresenius Medical came close to earning a declination under the FCPA Corporate Enforcement Policy. Unfortunately, Fresenius’ effort fell short — but it came close. Fresenius Medical operates more than 3700 dialysis clinics...more

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