Bracing For A Life Sciences Enforcement Zeitgeist: Part 2

By Gary Giampetruzzi and Sandra Gonzalez (November 3, 2017, 1:13 PM EDT) -- In the first part of this two-part article, we explored the risks attendant with German economic growth (noting that Germany is Europe's largest economy and the fourth largest economy in the world based on 2016 gross domestic product), as well as the investigative and enforcement mechanisms used by U.S. regulators to combat improper payments (i.e., bribes or kickbacks) in the U.S. ("over the past two decades, life sciences companies, in particular, have faced a virtual onslaught of U.S. government enforcement and have spent tens of billions of dollars in fines and penalties resulting from violations of various U.S. laws enacted to prevent and deter fraud and abuse") and around the world ("a staggering increase in FCPA enforcement with 2016 bringing a record number of FCPA resolutions accompanied by fines and penalties totaling $2.43 billion, including approximately $610 million recovered from eight life sciences companies"). In the second part of this article, we outline reasonable compliance measures that companies can take to help mitigate these risks....

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