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. ...
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