Companies searching for guidance on good Foreign Corrupt Practices Act compliance can learn a thing or two from the Johnson & Johnson case—not only about what the company did right, but where it went wrong, too.
The pharmaceutical and healthcare giant agreed to pay a total of $70 million in a settlement with the Justice Department announced on April 8: $21.4 in criminal penalties, along with $48.6 million in disgorgement and other fines. The settlement stemmed from J&J’s admission in 2007 that its British subsidiary DePuy Inc. had paid bribes to government officials in Greece, Romania and Poland since 1998. Michael Dormer, the J&J executive who was responsible for oversight of DePuy, resigned from the company in 2007.
