Lessons Learned from Pfizers Settlement of FCPA Claims
By THE GLOBAL COMPLIANCE & DISPUTES PRACTICE
On August 7, 2012, Pfizer announced a settlement with the Department of Justice and the Securities and Exchange Commission of criminal and civil claims related to alleged violations of the Foreign Corrupt Practices Act (the FCPA) by two of its subsidiaries. The settlement recognized Pfizers timely voluntary disclosure; its thorough and wide-reaching self-investigation of the underlying and related conduct; the extraordinary cooperation provided by the company to the DOJ and the SEC; its early and extensive remedial efforts; and the companys substantial and continuing improvements to its global anti-corruption compliance procedures. This Alert discusses some of the unique components of the settlement and the continued evolution of the governments approach to settlements of FCPA charges, and offers takeaways for other companies seeking to improve their compliance programs.