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FCPA Scorecard Blog

Foreign Corrupt Practices Act & Anti-Corruption


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  • Another Medical Device Case: Philips Settles SEC Administrative Proceeding for $4.5 Million

    On April 5, 2013, Koninklijke Philips Electronics, N.V., the Dutch parent of the Philips group of companies, settled an SEC administrative proceeding for more than $4.5 million.  The SEC alleged that Philips violated the internal controls and books and records provisions of the FCPA based on improper payments by employees of its Polish subsidiary to Polish government officials from 1999-2007 in connection with contracts for medical equipment.  The SEC cited Philips’s voluntary disclosure of the improprieties and subsequent remedial measures in deciding to accept the settlement.

    Poland Philips

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  • Eli Lilly Settles SEC FCPA Claims for $29.4 Million

    On December 20, 2012, Eli Lilly & Co. settled an enforcement action filed the same day by the SEC for nearly $29.4 million.  The SEC alleged that Lilly subsidiaries in Russia, Brazil, China and Poland made improper payments to government officials to obtain or retain business and that Lilly itself knew of the payments by the Russian subsidiary but did not act to stop the conduct for more than five years.

    China Brazil Russia Poland Eli Lilly

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