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Issues To Consider From The Cardinal Health Enforcement Action

Issues

This recent post highlighted the SEC’s $8.8 million Foreign Corrupt Practices Act enforcement action against Cardinal Health.

This post continues the analysis by highlighting additional issues to consider.

Timeline

According to the SEC order, “In December 2016, Cardinal voluntarily disclosed the results of its investigation to the Commission staff and subsequently cooperated with its investigation.”

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Cardinal Health Resolves $8.8 Million Enforcement Action Based On A Former Entity Maintaining And Operating Marketing Accounts For Certain Customers In China

cardinalhealth

Last Friday the SEC announced that Cardinal Health Inc. agreed to pay $8.8 million to resolve a Foreign Corrupt Practices Act enforcement action.

The action is based on a Cardinal entity (acquired in 2010 and sold in 2018) maintaining and operating marketing accounts for certain customers in China.

In summary fashion, the SEC order states:

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DOJ Deputy Assistant Attorney General Miner On “The Two Primary Goals Of White Collar Criminal Enforcement” (With Commentary)

miner

It’s mid-September which means a few things: the days are getting shorter, the trees are beginning to show color, and DOJ and SEC enforcement officials are on the speaking circuit.

Earlier this week it was SEC Chairman Jay Clayton (see here for the prior post) and yesterday it was DOJ Deputy Assistant Attorney General Matthew Miner who spoke on the two primary goals of white collar criminal enforcement: “(1) to deter legally non-compliant behavior and punish it where it does occur; and (2) to encourage greater compliant behavior, including creating a more level playing field for those who play by the rules.”

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Friday Roundup

Roundup

Quotable, sentenced, scrutiny updates, dismissed and for the reading stack. It’s all here in the Friday roundup.

Quotable

In a recent Corporate Crime Reporter interview, former DOJ FCPA prosecutor Ephraim Wernick was asked if FCPA enforcement has changed under the Trump administration and stated:

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Deputy Assistant Attorney General Matthew Miner On ….

miner

Recently Deputy Assistant Attorney General Matthew Miner delivered this speech at an American Bar Association event in Prague.

During the speech, Miner touched upon international cooperation; the DOJ’s so-called “no piling on” policy; the DOJ’s “Evaluation of Corporate Compliance Programs” guidance document; gathering evidence in foreign countries; voluntary disclosure, cooperation and so-called declinations; and enforcement actions against foreign companies.

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