Fresenius Medical FCPA Archives - Corruption, Crime & Compliance

2019 FCPA Enforcement Highlights (Part II of III)

Uncategorized

7 Jan, 2020

2019 FCPA Enforcement Highlights (Part II of III)

In a record year, there are bound to be numerous interesting enforcement actions and principles. I picked out a few to highlight. It is surprising to say the least that DOJ continues to return large enforcement actions against a number of global companies. You would think after the last ten years of aggressive enforcement companies would refrain from bribery schemes or dedicate resources to cleaning...

Fresenius Medical’s Bribery Conduct Precludes Declination (Part II of III)

General

2 Apr, 2019

Fresenius Medical’s Bribery Conduct Precludes Declination (Part II of III)

Fresenius Medical came close to earning a declination under the FCPA Corporate Enforcement Policy. Unfortunately, Fresenius’ effort fell short — but it came close. Fresenius Medical operates more than 3700 dialysis clinics worldwide and has 37 production sites in various countries. Fresenius’ relationship with third-party agents and distributors created significant risks. These relationships, in a number of high-risk countries, were used to funnel bribery payments. ...