Ratting Out The Competition: New DOJ Strategies

Law360, New York (March 28, 2012, 1:13 PM EDT) -- In a speech given Nov. 12, 2009, in front of an audience of large pharmaceutical and device company attorneys, compliance officers and executives, Lanny Breuer, assistant attorney general in the U.S. Department of Justice Criminal Division’s Fraud Section stated that the application of the Foreign Corrupt Practices Act to the pharmaceutical industry would be “one area of criminal enforcement that will be a focus for the Fraud Section in the months and years ahead.”[1]

Sure enough, within several months, more than five pharmaceutical and device companies reported in their 10-K filings that they had received “letters of inquiry” from the DOJ...

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