Swiss pharmaceutical and healthcare company Novartis AG, along with current subsidiary Novartis Hellas S.A.C.I. and former subsidiary Alcon Pte Ltd, have settled alleged FCPA charges by paying a combined amount of more than $346 million. This was not parent company Novartis AG’s first FCPA rodeo, but it managed to avoid the appointment of a monitor. The settlements stem largely from gifts, travel and entertainment and other improper payments the Novartis subsidiaries provided to healthcare providers in both Greece and Vietnam. The settlements may represent a renewed focus on GTE, and there are some important lessons here for other organizations in merger and acquisition mode, as well as for recidivists. See “Travel Agency Abuse, Falsified Expense Reports and Other Hospitality Blunders Lead to $25 Million Novartis Settlement
” (Apr. 6, 2016).