Life Science Compliance Update

September

2018

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

Written by , Posted in Uncategorized

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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