Checking In On Dr. Reddy’s FCPA Scrutiny
Several instances of FCPA scrutiny have dragged on for years including the scrutiny of Dr. Reddy’s Laboratories Ltd., (an India-based pharmaceutical company with ADRs listed on the New York Stock Exchange).
As highlighted in this prior post, in 2020 the company disclosed that it “has commenced a detailed investigation into an anonymous complaint” alleging that “healthcare professionals in Ukraine and potentially in other countries were provided with improper benefits in violation of U.S. laws.”
As highlighted in this prior post, in mid-2021 the company’s scrutiny expanded and in 2023 the company stated:
The Gray Cloud Of FCPA Scrutiny
This recent post highlighted the origins of corporate Foreign Corrupt Practices Act enforcement actions in 2025.
Continuing with the 2025 FCPA statistical feast, this post follows the chronology of scrutiny to enforcement and highlights one of the most troubling policy issues when it comes to FCPA enforcement.
That is – FCPA scrutiny simply lasts too long. In the FCPA’s modern era, FCPA scrutiny has tended to last approximately 4 years.
In 2025, there were three corporate FCPA enforcement actions making a median analysis less relevant than certain previous years.
In these three enforcement actions, the length of FCPA scrutiny was approximately 1.5 years, 5 years, and 5 years.
First, some general background.
Five Years Later, Dr. Reddy’s Is Still Under FCPA Scrutiny
Several instances of FCPA scrutiny have dragged on for years including the scrutiny of Dr. Reddy’s Laboratories Ltd., (an India-based pharmaceutical company with ADRs listed on the New York Stock Exchange).
As highlighted in this prior post, in 2020 the company disclosed that it “has commenced a detailed investigation into an anonymous complaint” alleging that “healthcare professionals in Ukraine and potentially in other countries were provided with improper benefits in violation of U.S. laws.”
As highlighted in this prior post, in mid-2021 the company’s scrutiny expanded and in 2023 the company stated:
Issues To Consider From The Liberty Mutual Enforcement Action
This previous post highlighted the $4.7 million FCPA enforcement action against Liberty Mutual concerning an alleged bribery scheme involving a foreign subsidiary in India.
This post highlights additional issues to consider.
Timeline
According to the DOJ, Liberty Mutual made a “timely and voluntary self-disclosure of the misconduct to the Fraud Section in March 2024, which was identified during an internal investigation that was still ongoing at the time of the disclosure.”
Seven Years Later, GE Healthcare Scrutiny Ends
Remember when a high-ranking Department of Justice official declared in 2017 that it was the intent of the DOJ “for our FCPA investigations to be measured in months, not years”? (See here for the prior post).
The recent DOJ memo titled “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act” states that prosecutors shall “proceed as expeditiously as possible in their investigations.”
Despite years of DOJ (and SEC) statements about the importance of expeditious FCPA investigations, the fact remains that FCPA scrutiny tends to last approximately 4-5 years on average with several instances of FCPA scrutiny lasting longer.
Case in point – GE Healthcare.