Last week Bristol-Myers Squibb announced that the Justice Department has decided to prosecute the company for a criminal Foreign Corrupt Practices Act.  The news was tucked away in a Form 10-Q, which BSM had filed with the Securities and Exchange Commission on Oct. 27. It stated in part, “The company has also been advised by the Department of Justice that it has closed its inquiry into this matter.”

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Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in...