This previous post highlighted the SEC’s recent $7.8 million enforcement action against medical device company Stryker.
This post continues the analysis by highlighting additional issues to consider.
Two Ways to Look at Repeat Offenders
As highlighted in the prior post, Stryker is now in the FCPA repeat offender club. There are two ways to look at certain of the companies on the list.
On the one hand, one could view these companies as corrupt companies without a commitment to compliance who did not learn any lesson from the first time the company resolved an FCPA enforcement action.