Sanctions ​And Export Control Risks For Health Care Cos.

Law360, New York (May 19, 2017, 3:49 PM EDT) -- Over the past 15 years, pharmaceutical manufacturers, medical device companies and other participants in the health care industry have been regular targets of U.S. Foreign Corrupt Practices Act enforcement actions brought by the U.S. government. FCPA cases levied against health care companies have commanded significant attention, and many companies have responded by implementing robust anti-corruption compliance programs consisting of policies and procedures, employee training, risk-based due diligence and proactive compliance testing and monitoring.

Recent settlements suggest that a new trend may be emerging: the U.S. government...
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