Managing Continued FCPA Scrutiny in Pharmaceutical Industry

Pharmaceutical Compliance Monitor
01.21.16
In this article, Marc Alain Bohn discusses continued Foreign Corrupt Practices Act (FCPA) scrutiny of pharmaceutical companies. In remarks at a pharmaceutical congress in March 2015, Andrew Ceresney, director of the U.S. Securities and Exchange Commission's Division of Enforcement, asserted that the Commission has been focused on FCPA enforcement across the pharmaceutical industry in recent years. "In the face of such scrutiny, pharmaceutical companies need to be attuned to the unique and evolving risks confronting their industry and implement compliance programs that effectively mitigate these risks," Bohn said. He suggests that pharmaceutical companies identify red flags and minimize risk violations in order to remain compliant under enhanced scrutiny. "While altogether eliminating corruption risk is not possible, pharmaceutical companies that remain attuned to the evolving compliance challenges confronting their industry and adapt their programs accordingly will be best positioned to respond to any scrutiny they receive from enforcement authorities," he said.
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