Fresenius Medical FCPA Archives - Corruption, Crime & Compliance

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...

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. ...