Bio-Rad, a California-based medical diagnostics and life sciences manufacturing and sales company, has agreed to pay $55 million to settle criminal and civil allegations that it violated the FCPA by making improper payments to foreign officials in Russia, Vietnam and Thailand to win government business. The SEC and DOJ said the company had a decentralized and weak system of internal controls, but that its cooperation and investigation were extensive after it voluntarily disclosed the problems. In Thailand, the entity that made the bribes had just been acquired by Bio-Rad, demonstrating the importance of pre-merger diligence. See also “Checklist of Actions to Take and Factors to Consider When Conducting Pre-Merger Anti-Corruption Due Diligence
” (Sep. 26, 2013).