‘Tis the Season: Gifts, Travel, and Entertainment and the FCPA Resource Guide
The holiday season is quickly upon us—time to find the perfect gifts for family and friends, enjoy holiday parties, and remember to help those less fortunate. In many cultures around the world, the...
View ArticleManaging Your FCPA Risk: Lessons for the Device Industry from 2012...
Just as the start of a new year leads individuals to reflect on the year just ended and make resolutions for the year to come, the dawn of 2013 represents the perfect time for medical device companies...
View ArticleAnti-Corruption Developments in 2012 and What to Watch for in 2013
Covington recently released its annual Anti-Corruption Year in Review, highlighting enforcement activities in 2012 and offering our view on what to watch for in 2013. Besides the release of the...
View ArticleDeferred Prosecution Agreements in the UK: One Step Closer to the...
Just days before the UK Parliament broke up for its February recess, the introduction of deferred prosecution agreements (“DPAs”) in the UK came a step closer to realization when the Crime and Courts...
View ArticleZimmer Holdings Announces Declinations from DOJ, SEC for FCPA Investigations
Medical device maker Zimmer Holdings Inc. recently announced that it had received letters of declination from the US Department of Justice (“DOJ”) and US Securities and Exchange Commission (“SEC”)...
View ArticleFCPA Enforcement Action Against China-Based Company and Lessons for the...
The first Foreign Corrupt Practices Act (“FCPA”) enforcement action of the year, which also appears to be the first FCPA-related enforcement action against a China-based company, underscores key areas...
View ArticleSpotlight on Latin America: Brazil’s New Clean Companies Act
Following months of widespread public protests against official corruption in Brazil, Brazilian President Dilma Rousseff signed into law the Brazilian Clean Companies Act (“Act”) on August 1, 2013....
View ArticleChina Launches Review of Medical Device Industry
Two agencies in the Chinese government have initiated plans to review the levels of use and the pricing of medical devices marketed in China. This news comes in the midst of several other...
View ArticleSpotlight on China: What Does the Chinese Government’s Investigation of the...
In late June 2013, the Chinese government announced that it had detained four senior executives of GlaxoSmithKline for alleged economic crimes. The Ministry of Public Security alleged that, since...
View ArticleAnother Medical Device Company is Cleared, Coming Off A Long List of Open...
For over five years, Medtronic, Inc. (Medtronic), a Minnesota-based medical technology company, had been the subject of open investigations by the US Securities and Exchange Commission (SEC) and the US...
View ArticleDodd-Frank Whistleblower Program and the FCPA: What Does it Mean for Your...
In August 2011, the SEC’s new whistleblower program under the Dodd-Frank Act took effect, requiring the SEC to pay a cash award to any individual who voluntarily provides the SEC with original...
View Article“Foreign Official” Under the FCPA: The First U.S. Appellate Court Weighs In
On May 16, 2014, in United States v. Esquenazi, the U.S. Court of Appeals for the Eleventh Circuit issued the first appellate opinion considering the scope of the term “foreign official” under the...
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