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...
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- Root Cause Analysis: A Critical Ethics and Compliance Practice February 25, 2021
- FCPA Themes from 2020 with Compliance Commentary February 19, 2021
- Common Pitfalls – Fraud Risk Assessment February 12, 2021
- The Continued Evolution of Best Practices for Compliance Programs! February 10, 2021
- Red Flags That May Indicate You Might be at Risk of Violating FCPA February 3, 2021