James Tillen and Matt Reinhard* comment on the DOJ’s increased focus on FCPA violations by pharmaceutical companies. “What we see,” Tillen and Reinhard told BNA, “is a recurring pattern where the DOJ identifies a particular industry that it considers to have substantial risk or exposure to foreign corrupt payments and launches an investigation. What may start with one or two companies can quickly mushroom as the DOJ becomes more familiar with the underlying industry conduct, or a particular region, or local practice. In the realm of pharmaceuticals, it is conceivable the DOJ could start with the investigation of one or two companies operating in a particular region, or with respect to a particular tender of pharmaceuticals,” they continued.

*Former Miller & Chevalier attorney