Two years after the Chinese government fined GlaxoSmithKline $490 million for bribing health care practitioners there, the SEC has resolved FCPA charges with the company for $20 million for the same conduct. The settlement “does not refer to profit or gain figures, or tie the fine to such figures,” Gary DiBianco, a partner at Skadden, told the Anti-Corruption Report, which may mean the SEC took into account the Chinese government’s penalty. The DOJ declined to prosecute. The settlement is the latest in a series of FCPA actions against pharmaceutical companies. As a result of those investigations, compliance obligations negotiated as a part of settlements and proactive compliance improvements, anti-corruption programs in the pharmaceutical sector have evolved to be among the most sophisticated among all multinational corporations, DiBianco said. See also “Seven Lessons From China’s Bribery Investigation of GlaxoSmithKline
” (Aug. 7, 2013).