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.

Recently, the company disclosed:

“Government Disclosures

From time to time, we make self-disclosures regarding our compliance with the Foreign Corrupt Practices Act (“FCPA”) and similar laws to relevant authorities who may pursue or decline to pursue enforcement proceedings against us. We, with the assistance of outside counsel, made voluntary self-disclosures to the U.S. Securities and Exchange Commission (“SEC”) and the U.S. Department of Justice (“DOJ”) beginning in 2018 regarding tender irregularities and other potential violations of the FCPA relating to our activities in certain provinces in China. We fully cooperated with the reviews by these agencies and implemented, and continue to implement, enhancements to our compliance policies and practices. We received letters from the SEC on May 16, 2025 and the DOJ on May 28, 2025 closing their respective investigations without further action.”