Sanofi settles FCPA charges with SEC for $25.2 million

Abstract

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.

Citation

Park, J.K. 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. https://doi.org/10.1108/JOIC-01-2019-0005