U.S. Medical Device Company in France Resolves FCPA Issues Internally

A U.S. public medical-device company engaged Faegre Drinker to lead an FCPA internal investigation into sales practices; the use of third-party intermediaries; consulting relationships; and gift, travel and entertainment issues involving health care professionals in France. The result was revised third-party intermediary due-diligence and on-boarding process, enhanced contracts, enhanced oversight, and misconduct discontinued. We recommended no voluntary disclosure.