Entries tagged: fcpa

Lessons Learned From The Novartis FCPA Settlement

By: Jack Harrington, Esq.

Posted: July 25th, 2016

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    Last spring, Swiss pharmaceutical giant Novartis AG paid $25 million to the SEC to settle Foreign Corrupt Practices Act (“FCPA”) charges relating to its operations in China.  According to the SEC’s internal administrative order, Novartis subsidiaries in China bribed government-affiliated doctors and healthcare professionals—who qualify as “foreign officials” under the FCPA—to increase sales […]

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Princelings: Expanding the Definition of “Value” Under the FCPA

By: Jack Harrington, Esq.

Posted: May 6th, 2016

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    Congress enacted the Foreign Corrupt Practices Act (“FCPA”) in 1977 in the wake of the Watergate investigation and in response to reports of widespread bribery of foreign officials by U.S. companies.  The FCPA prohibits U.S. persons, companies, and issuers from, among other things, bribing or attempting to bribe a foreign official in order […]

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The SEC Reminds Us: An Ounce of Prevention is Worth a Pound of Cure

By: Jack Harrington, Esq.

Posted: November 20th, 2015

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On November 4, 2015, Andrew Ceresney, the head of the Security and Exchange Commission’s (“SEC”) enforcement division, delivered the keynote address to the National Society of Compliance Professionals’ annual meeting.  The key takeaway from Mr. Ceresney’s remarks is that is the compliance function—and specifically the role of the Chief Compliance Officer (“CCO”)—is more important than […]

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