Life Science Compliance Update

September

2018

More Pain, Higher Up the Chain Is on The FCPA Enforcement Horizon

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By: Michael Trahar

Growing reliance on third parties to administer the touchpoints between life sciences companies and foreign officials risks criminal liability for enterprises and individuals high in management, if regulators view the third-party contracts as designed to facilitate corruption. Lessons learned from past enforcement actions and improved compliance policies mean these contracts are approved at ever-higher levels of management, but revenue flows through third parties are becoming less transparent.


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    February

    2018

    Revisiting the Past – Warner Chilcott vs. Insys

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    Kaitlin Fallon Wildoner, Esq., Senior Staff Writer, Life Science Compliance Update

    Those who remember the Warner Chilcott and W. Carl Reichel case from just two years ago may have had déjà vu when they heard about the recent legal controversy surrounding John N. Kapoor and Insys. This article reviews the current Insys and Kapoor developments and compares the two cases to analyze whether the trend of involving high-ranking executives is the future of enforcement.


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