Bristol-Myers Squibb Company agreed to pay over $14 million to settle SEC administrative proceedings alleging FCPA violations from 2009-2014 in connection with payments to HCPs in China.
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DOJ Attempts to Clarify Corporate Cooperation Credit Expectations
In a recent speech at NYU Law School, Assistant Attorney General Leslie Caldwell attempted to provide guidance to companies seeking cooperation credit from the Justice Department. She warned of dire consequences if a company fails to cooperate, but stated that DOJ does “not expect companies to aimlessly boil the ocean” during internal investigations.
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