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Issues To Consider From The Cardinal Health Enforcement Action

By Mike Koehler on March 3, 2020 in Cardinal Health, Gray Cloud, Merger Issues, Syncor

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.”

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

By Mike Koehler on March 2, 2020 in 2020 Enforcement Action, Cardinal Health, Gifts, Merger Issues, Pharmaceutical Industry, SEC Enforcement Action, Travel and Entertainment

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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Issues To Consider From The Cardinal Health Enforcement Action

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

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