Top Menu

Navigation

FCPA Repeat Offender Stryker Discloses FCPA Scrutiny

By on May 3, 2023 in Repeat Offenders, Stryker Corp.
stryker

As highlighted in this prior post, in 2013 Stryker resolved a $13.2 million Foreign Corrupt Practices Act enforcement action based on alleged conduct in Mexico, Poland, Romania, Argentina, and Greece.

As a condition of settlement, Stryker agreed to cease and desist from committing or causing any violations and any future violations of the FCPA’s books and records and internal controls provisions.

The SEC order also contained a separate section titled “Stryker’s Remedial Efforts” and stated among other things:

Continue Reading

Sixth Circuit Concludes That Just Because The United Nations Convention Against Corruption Requires That American Courts Be Available To Foreign Plaintiffs In Corruption Cases Does Not Mean “That Foreign States Win In Our Courts No Matter The Merits Of Their Arguments”

By on March 22, 2022 in Related Civil Litigation, Stryker Corp., Uncategorized, United Nations Convention Against Corruption
Judicial Decision

As highlighted in this prior post, in 2013 Stryker resolved a $13.2 million enforcement action based on alleged conduct in Mexico, Poland, Romania, Argentina, and Greece.

As to the Mexico conduct, the SEC found: “Between March 2004 and January 2007, Stryker’s wholly-owned subsidiary in Mexico (“Stryker Mexico) made three payments totaling more than $76,000 to foreign officials employed by a Mexican governmental agency (the “Mexican Agency”) responsible for providing social security for government employees. Stryker made these payments to win bids to sell its medical products to certain public hospitals in Mexico.”

Continue Reading

Appellate Court To Decide If The U.S. Is An Appropriate Forum For The Mexican Government To Sue Stryker For Damages In Connection With A 2013 FCPA Enforcement Action

By on May 18, 2021 in Related Civil Litigation, Stryker Corp.
stryker

This previous post highlighted how the Mexican government (specifically Instituto Mexicano del Seguro Social (IMSS) – the Mexican Social Security Institute) filed a civil action against Stryker Corporation in connection with its 2013 Foreign Corrupt Practices Act enforcement action concerning conduct in, among other countries, Mexico.

As to the Mexico conduct, the SEC found in the enforcement action:

Continue Reading

Mexican Government Sues Stryker In Connection With 2013 FCPA Enforcement Action

By on October 24, 2019 in Related Civil Litigation, Stryker Corp.
stryker

As highlighted in this prior post, in 2018 Stryker (a Michigan-based medical device company) became an FCPA repeat offender as the SEC brought a $7.8 million enforcement action against the company for not having internal accounting controls “sufficient to detect the risk of improper payments in sales of Stryker products in India, China, and Kuwait” and because “Stryker’s India subsidiary failed to maintain complete and accurate books and records.”

As highlighted in this prior post, in 2013 Stryker resolved a $13.2 million enforcement action based on alleged conduct in Mexico, Poland, Romania, Argentina, and Greece.

As to the Mexico conduct, the SEC found:

Continue Reading

Issues To Consider From The Stryker Enforcement Action

By on October 3, 2018 in Internal Controls, Repeat Offenders, Stryker Corp., Uncategorized
Issues

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.

Continue Reading

Powered by WordPress. Designed by WooThemes