Stryker
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.”
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.
Bombardier
As highlighted in this prior post post, in mid-2019 it was reported:
“Bombardier Inc. is hiring an independent organization to review its procedures for doing business in foreign markets in the wake of allegations that company officials used corruption and collusion to win a rail contract in Azerbaijan. The Canadian airplane and train maker said in its second-quarter financial statements that it will work with a third-party group chosen by Export Development Canada “to evaluate our existing due diligence processes.” EDC helps Canadian exporters through insurance and financing and has been involved in billions of dollars of Bombardier contracts in overseas markets.”
In 2020, the United Kingdom Serious Fraud Office a release stating: “The SFO confirms it is investigating Bombardier Inc over suspected bribery and corruption in relation to contracts and / or orders from Garuda Indonesia.”
In 2024, it was reported:
“The UK’s Serious Fraud Office closed its investigation into bribery and corruption allegations at Bombardier Inc., deferring to comparable probes in the US and Canada. The SFO opened its investigation into the company’s dealings with PT Garuda Indonesia in 2020. The airline ordered Bombardier CRJ regional jets, with the first delivery in 2012. The overseas authorities are best placed to progress with the case, the prosecutor said in a statement Monday. The UK prosecutor will work with investigators in other countries to “deliver justice globally,” the SFO said. Bombardier said in a statement that it continued to “cooperate with the authorities in Canada and the US.”
Bombardier recently disclosed:
“U.S. Department of Justice
On February 10, 2020, Bombardier received a letter from the U.S. Department of Justice (the “DOJ”) requesting the communication of documents and information regarding the ADY Contract [Azerbaijan
Railways]. The Corporation’s internal review about the reported allegations is on-going but based on information known to the Corporation at this time, there is no evidence that suggests a corrupt payment was made or offered to a public official or that any other criminal activity involving Bombardier took place.The DOJ also made requests regarding contracts in South Africa and Indonesia, as well as requests
with respect to other sales of aircraft and services. Bombardier is cooperating with the DOJ’s requests. With respect to the Indonesia matter, in May 2020, the Indonesian Corruption Court convicted the former CEO of Garuda Indonesia (Persero) TBK (“Garuda”) and his associate of corruption and money laundering in connection with five procurement processes involving different manufacturers, including the 2011-2012 acquisition and lease of Bombardier CRJ1000 aircraft by Garuda (the “Garuda Transactions”). No charges were laid against the Corporation or any of its directors, officers or employees. Shortly thereafter, the Corporation launched an internal review into the Garuda Transactions, which is being conducted by external counsel.On April 1, 2025, the DOJ informed the Corporation that following a review of the Indonesia and ADY Contract matters, and based on the information the DOJ had learned to date, it had closed both investigations.”
