The SEC’s announcement that Boston-based Alexion Pharmaceuticals Inc. agreed to settle FCPA charges for some $21 million over inappropriate payments two subsidiaries made in Russia and Turkey marks the second FCPA resolution in the pharmaceuticals industry in less than two weeks, putting that industry back in the spotlight and demonstrates FCPA officials are still moving ahead with enforcement during the pandemic. We analyze the settlement and provide insight on how to mitigate the corruption risk associated with grant payments and honoraria. See “Novartis and Subsidiaries Settle FCPA Cases for $346M, Avoiding a Monitor Despite Recidivism
” (Jul. 8, 2020).