In 2012, companies and executives operating in the healthcare and life sciences industries had an outsize presence in Foreign Corrupt Practices Act (FCPA) enforcement actions. Given recent Department of Justice (DOJ) and Securities and Exchange Commission (SEC) pronouncements, coupled with more companies deciding to voluntarily disclose and seek greater leniency by providing information regarding their employees and competitors, it appears that the world of healthcare, pharmaceuticals, and medical devices will continue to figure prominently in FCPA enforcement.
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