Pfizer's FCPA Settlement Provides Important Lessons for the Medical Products Industry on Compliance Program Expectations
On August 7, 2012, Pfizer Inc. (Pfizer) announced the resolution of a previously disclosed investigation by the U.S. government into its relationships with healthcare providers (HCPs) and government officials outside of the United States. To resolve alleged criminal violations of the U.S. Foreign Corrupt Practices Act (FCPA), Pfizer subsidiary Pfizer H.C.P. Corporation (Pfizer H.C.P.) entered into a two-year Deferred Prosecution Agreement (DPA) with the U.S. Department of Justice (DOJ) and agreed to the filing of a two-count information charging the company with bribery and conspiracy to violate the FCPA. As part of the agreed-upon criminal settlement, Pfizer H.C.P. admitted the facts of the Information as true, and paid a fine of US$15 million.