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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    January

    2018

    Christmas Comes Early – The FCPA Pilot Program Made Permanent

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    Jenny McVey, Associate Director, Forensic Risk Alliance

    When we first introduced the FCPA Pilot Program in the June 2016 issue, we noted the uncertainties of outcomes for companies who voluntarily self-disclose potential violations. On November 29, 2017, Deputy Attorney General Rod Rosenstein announced that the US Department of Justice (DOJ) had made the FCPA Pilot Program permanent. This article will review some of the key highlights outlined by the DOJ and some considerations for compliance professionals.


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