This post highlights nine Foreign Corrupt Practices Act enforcement actions concerning conduct (in whole or in part) in Greece.
The enforcement action concerned conduct in Greece, Vietnam and South Korea.
As to Greece, the allegations were: “Novartis Greece, through its employees and agents, knowingly and willfully conspired and agreed to corruptly provide improper benefits and things of value to employees of state-owned and state-controlled hospitals and clinics in Greece (“Greek State HCPs”) and other HCPs in Greece with the intent to obtain an improper advantage and to increase sales of a certain Novartis-branded prescription drug in Greece. Specifically, Novartis Greece sponsored Greek State HCPs to attend international congresses as a means to bribe and corruptly influence the HCPs to increase prescriptions of Lucentis a drug to treat adults with age-related macular degeneration].
This post highlights FCPA enforcement actions concerning conduct (in whole or in part) in Georgia and Ukraine.
Georgia
The enforcement action concerned conduct in Georgia and the allegations were: “From approximately November 2006 to December 2009, Linde, through Spectra Gases, Inc., a company that Linde acquired in October 2006, made corrupt payments to high-level officials at the National High Technology Center (NHTC) of the Republic of Georgia, a 100% state-owned and-controlled entity, in connection with its purchase of certain income-producing assets from the NHTC.”
This post highlights 8 FCPA enforcement actions concerning conduct (in whole or in part) in Poland.
The enforcement action concerned conduct in Russia, Poland and Mexico.
As to Poland, the allegations were: HP Poland “(i) caused the falsification of HP’s books and records; and (ii) circumvented HP’s existing internal controls, in connection with a scheme to make corrupt payments to one or more foreign officials in Poland, including the Polish Official [the Director of Information and Communications Technology within the Polish National Police Agency (“KGP”) which was part of the Polish Ministry of the Interior and Administration].” Between 2006 and 2010 HP Poland “provided Polish Official cash worth the equivalent of approximately $600,000, gifts valued in excess of $30,000, and several thousand dollars in improper travel and entertainment benefits.” “During this same time span, the Polish government awarded to HP Poland at least seven contracts for KGP-related information technology products and services, with a total value of approximately $60 million.”
In 2019, Alvaro Pulido Vargas was criminally charged with laundering the proceeds of violations of the FCPA in connection with a scheme to pay bribes to take advantage of Venezuela’s government controlled-exchange rate. (See here).
In 2021, the DOJ also announced the unsealing of an indictment charging various individuals including Alvaro Pulido Vargas for their alleged roles in laundering the proceeds of contracts to provide food and medicine to Venezuela that were obtained through bribes. (See here for the prior post).
Yesterday, the DOJ announced that Pulido Vargas was arrested and will be making an initial appearance on October 13th in the Southern District of Florida to face federal prosecution.
This post highlights seven FCPA enforcement actions concerning conduct (in whole or in part) in South Africa.
The enforcement action concerned conduct in South Africa and Nepal.
As to South Africa, the allegations were: “between January 2016 and at least January 2020, AAR, through its agents, knowingly and willfully conspired and agreed with others to corruptly offer and pay bribes to, and for the benefit of, government officials in South Africa […] to secure improper advantages in order to assist AAR in obtaining and retaining business from SAAT [South African Airways Technical – a wholly owned subsidiary of South African Airways – that provided technical services for SAA and other airlines], namely the award of a five-year aircraft component support contract (“SAAT Contract”) and disbursement of payments by SAAT pursuant to that contract.”