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Health Law

United States Foreign Corrupt Practices Act

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On February 12, 2007, Johnson & Johnson acknowledged that it had disclosed to the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) “that subsidiaries outside the United States are believed to have made improper payments in connection with the sale of medical devices in two small-market countries.” That announcement highlights the risks for the medical device industry of violating the Foreign Corrupt Practices Act (FCPA) and reflects a more pervasive trend of increased FCPA enforcement.

Please click on the PDF link above to view the full alert.