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 Anti-Corruption 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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