The SEC has made no secret that it is focused on bribes made by pharmaceutical companies to Chinese health care practitioners, whom it considers foreign officials under the FCPA. Previous settlements with pharma companies operating in China - such as Eli Lilly, Biomet, Pfizer and Mead Johnson – have focused on the provision of gifts, travel, entertainment or simply cash to Chinese health care practitioners in exchange for prescribing products or getting on government formularies. On October 5, 2015, the SEC announced that it resolved similar charges with pharma giant Bristol-Myers Squibb (BMS) for over $14 million. The SEC says former BMS employees called their bribes an “open secret” and the only way to meet their sales targets. We analyze the settlement, a U-turn from the initial investigation into BMS’ activities in Germany, and some of the mistakes BMS made. See “Ceresney, Focusing on Pharma, Discusses SEC Enforcement Priorities and Compliance Expectations” (Mar. 18, 2015).