Sanofi settles FCPA charges with SEC for $25.2 million

Jennifer Kennedy Park (Cleary Gottlieb Steen and Hamilton LLP, New York, New York, USA)
Abena Mainoo (Cleary Gottlieb Steen and Hamilton LLP, New York, New York, USA)

Journal of Investment Compliance

ISSN: 1528-5812

Publication date: 7 May 2019



To explain a recent enforcement action by the US Securities and Exchange Commission (SEC) highlighting risk factors for Foreign Corrupt Practices Act (FCPA) violations.


Summarizes the basis of the SEC’s enforcement action against Sanofi for violating the FCPA’s books and records and internal controls provisions, reviews the terms of the SEC’s resolution with Sanofi, explains Sanofi’s remedial efforts and cooperation with the SEC’s investigation, and discusses factors contributing to corruption risks in the healthcare industry.


The SEC’s enforcement action against Sanofi, and other recent enforcement actions, underscore the importance of comprehensive anti-corruption compliance programs and strong internal controls across large multinationals and their subsidiaries.

Practical implications

Companies operating in high-risk industries and markets should regularly assess and address corruption risks.


Practical guidance from experienced enforcement lawyers.



Editor’s Note: This article was prepared with the assistance of Martine B. Forneret.


Park, J. and Mainoo, A. (2019), "Sanofi settles FCPA charges with SEC for $25.2 million", Journal of Investment Compliance, Vol. 20 No. 1, pp. 27-30.

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Copyright © 2019, Cleary Gottlieb Steen & Hamilton LLP.

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