Four Takeaways from Stryker’s $13 Million Civil Settlement of FCPA Internal Control Violations

Six years after disclosing the SEC and DOJ investigation into possible FCPA violations, Stryker Corporation, a Michigan-based medical device company, has agreed to an SEC Consent Order that requires it to pay $13.3 million in disgorgement, interest and fines.  Stryker was not charged with violating the anti-bribery provisions of the FCPA, only the accounting provisions.  The SEC found that Stryker made approximately $7.5 million in profits as a result of the improper payments to foreign officials from 2003-2008 in Mexico, Poland, Romania, Argentina and Greece, which were described in Stryker’s books as legitimate expenses such as travel, charitable donations consulting and commissions. As discussed in The FCPA Report’s Guide to Disclosing Corruption Investigations in SEC Filings, Stryker first disclosed the government’s SEC investigation and Stryker’s cooperation in November 2007.  

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