recidivist Archives - Corruption, Crime & Compliance

25 Jan, 2017

FCPA Recidivists: Zimmer Biomet (Part I of II)

It’s easier to fool people than to convince them they have been fooled – Mark Twain The drug and medical device industries have been taking it on the FCPA chin for years. The risk factors in the international marketplace are significant – (1) healthcare professionals are normally government employees; (2) government regulation of healthcare is robust; and (3) healthcare professionals are underpaid and therefore demand...

General

19 Jul, 2016

Johnson Controls Pays $14 Million for China FCPA Violations: DOJ Declines Prosecution

There’s something happening here, but what it is ain’t exactly clear – “For What It’s Worth,” Buffalo Springfield At first glance, the SEC’s recent enforcement action against Johnson Controls for $14 million for FCPA violations in China, along with a Justice Department declination under its new Pilot Program, appears to be a “routine” enforcement matter. Unfortunately, this case was anything but routine and there are...