Tagged: novartis alcon FCPA Enforcement

2020 Year in Review: Interesting Enforcement Actions (Part III of IV)

DOJ and the SEC each had a great year in FCPA enforcement.  But it is important to acknowledge that the blockbuster case, Goldman Sachs, was the driver of this successful year.  Goldman Sachs Goldman Sachs paid DOJ and the SEC nearly $4 billion in fines and disgorgement.  DOJ has reccivered nearly $1` billion in assets through its forfeiture initiative. Goldman Sachs was a massive and...

Novartis and Alcon: A Review of Bribery and Accounting Violations (Part II of III)

Novartis and Alcon engaged in separate but significant bribery schemes.  Considering the fact that Novartis had a similar violation in 2016 in China involving much of the same conduct, Novartis’ conduct reflects a weak corporate culture of compliance. Novartis’ conduct is all the more troubling given its enforcement record on domestic False Claims Act and anti-kickback prosecutions.  Novartis has real compliance and culture problems, apparently...

Novartis and Alcon Settle FCPA Violations for $345 Million (Part I of III)

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...

Episode 148 — A Review of the Novartis & Alcon FCPA Enforcement Action

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...