In 2013 Stryker resolved a $13.2 million Foreign Corrupt Practices Act enforcement action based on conduct in Mexico, Poland, Romania, Argentina, and Greece.
In 2018 Stryker resolved a $7.8 million FCPA enforcement action based on conduct in India, China, and Kuwait.
In 2023, Stryker disclosed:
“We are currently investigating whether certain business activities in a foreign country violated provisions of the Foreign Corrupt Practices Act (FCPA) and have engaged outside counsel to conduct this investigation. We have been contacted by the United States Securities and Exchange Commission and United States Department of Justice and are cooperating with both agencies. At this time we are unable to predict the outcome of the investigation or the potential impact, if any, on our financial statements.”
In May 2025, Stryker disclosed:
We are currently investigating whether certain business activities in certain foreign countries violated provisions of the FCPA and have engaged outside counsel to conduct these investigations. We have been contacted by SEC and DOJ and certain other regulatory authorities and are cooperating with these agencies. On April 1, 2025 we were informed by the DOJ that it had closed its inquiry into potential FCPA violations without further action. At this time we are unable to predict the outcome of the remaining investigations or the potential impact, if any, on our financial statements.
“As disclosed in our prior filings, we were previously contacted by the SEC, the United States Department of Justice, and other regulatory authorities involving whether certain business activities in certain foreign countries violated provisions of the FCPA and analogous local laws. We have completed our investigation into these matters. On April 1, 2025, and December 16, 2025, we were informed by the DOJ and SEC, respectively, that each agency had closed its inquiry. We are currently responding to inquiries by certain foreign authorities arising in the normal course of business, however, we do not expect these matters to have a material effect, if any, on our financial statements.”
