Life As an FCPA Recidivist: How Stryker’s Seemingly Minor Violations Became a Major Problem

Joining the ranks of FCPA recidivists, medical device company Stryker Corporation recently entered into its second FCPA settlement in five years. The company, which paid $13.3 million in November 2013 to resolve books and records and internal control violations relating to bribes it allegedly paid in Mexico, Poland, Romania, Argentina and Greece, recently resolved additional SEC charges under the same provisions. This time, Stryker’s internal controls failures were comparatively minor but its recidivism led to a $7.8 million penalty and an independent compliance consultant. See “LBI and Its Monitor Discuss Getting the Most Out of a Monitorship” (Aug. 2, 2017).

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