Fresenius Medical, the largest supplier of dialysis equipment and services agreed to pay $231 million to the Justice Department and the SEC to resolve FCPA violations in 17 countries in Africa, the Middle East and Europe.  Fresenius entered a non-prosecution agreement  with the Justice Department, in which it agreed to pay an $87 million payment and a two-year corporate monitor.  Fresenius agreed to enhance its compliance program and self-report to DOJ the third year.  In the SEC enforcement action, Fresenius agreed to disgorge $147 million in an administrative order.

In  this episode, Michael Volkov digs into the facts and reviews the bribery misconduct.