Lessons learned from Fresenius Medical FCPA settlement Archives

14 Apr, 2019

Episode 85 — A Deep Dive into the Fresenius Medical FCPA Settlement

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...

General

3 Apr, 2019

Lessons Learned from Fresenius Medical FCPA Settlement (Part III of III)

Fresenius Medical’s FCPA settlement for $231 million demonstrates again the continuing vitality surrounding the FCPA Corporate Enforcement Policy – which provides a carefully constructed framework for encouraging voluntary disclosures and FCPA enforcement. Fresenius earned a non-prosecution agreement and was not required to enter a deferred prosecution agreement and designate a subsidiary to plead guilty to an FCPA criminal offense. Additionally, given the geographic breadth of...