TY  - JOUR
AB  - Purpose To explain a recent enforcement action by the US Securities and Exchange Commission (SEC) highlighting risk factors for Foreign Corrupt Practices Act (FCPA) violations.Design/methodology/approach 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.Findings 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.Originality/value Practical guidance from experienced enforcement lawyers.
VL  - 20
IS  - 1
SN  - 1528-5812
DO  - 10.1108/JOIC-01-2019-0005
UR  - https://doi.org/10.1108/JOIC-01-2019-0005
AU  - Park Jennifer Kennedy
AU  - Mainoo Abena
PY  - 2019
Y1  - 2019/01/01
TI  - Sanofi settles FCPA charges with SEC for $25.2 million
T2  - Journal of Investment Compliance
PB  - Emerald Publishing Limited
SP  - 27
EP  - 30
Y2  - 2024/04/25
ER  -