Tom Fox and I recently had a chance to discuss the Fresenius Medical FCPA enforcement action. A link to the podcast is here.

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.