Even during this difficult time of the pandemic, economic uncertainty and social unrest, the Justice Department and the SEC have concluded a major FCPA enforcement action. 

Novartis and Alcon (which was a Novartis subsidiary at the time of the misconduct) agreed to pay a total of $345 million in criminal and civil penalties.  Novartis spun off Alcon in 2019.

Under the DOJ settlement, Novartis and Alcon each entered into a deferred prosecution agreement; Novartis agreed to pay a fine of $225 million and Alcon agreed to pay $8.9 million in criminal penalties.  Novartis also entered into a settlement with the SEC under which they agreed to pay a total of $112 million.

In this Episode, Michael Volkov reviews the DOJ and SEC settlements and the underlying conduct.