Sanofi SEC Settlement Offers Lessons on Pharma Discounts, Samples and Receipts

French pharmaceutical giant Sanofi recently settled books-and-records and internal controls issues with the SEC, months after receiving a DOJ declination. “Bribery in connection with pharmaceutical sales remains as a significant problem despite numerous prior enforcement actions involving the industry and life sciences more generally,” Charles Cain, FCPA Unit Chief at the SEC, observed in a press release. “While bribery risk can impact any industry, this matter illustrates that more work needs to be done to address the particular risks posed in the pharmaceutical industry,” he said. The company used common techniques to funnel bribes to officials in Kazakhstan and the Middle East, and the settlement provides lessons about how to properly manage discounts, samples and GT&E expenses. See “Teva’s $519 Million FCPA Settlement Highlights Hazards of Local Production Requirements” (Jan. 18, 2017).

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