Michigan-based medical equipment manufacturer Stryker disclosed it is investigating whether certain of its business activities might have violated the Foreign Corrupt Practices Act (FCPA).

Stryker said in a regulatory filing with the Securities and Exchange Commission (SEC) on Tuesday it hired outside counsel to conduct an investigation. The company didn’t name in which country outside the United States the questionable activities might have occurred.

Stryker said it’s been contacted by the SEC and the Department of Justice and is “cooperating with both agencies.”

The company previously settled SEC charges of violating the FCPA twice in the last decade.

In September 2018, Stryker agreed to pay a $7.8 million penalty to settle allegations the company violated the books and records and internal accounting controls provisions of the FCPA regarding deficiencies in its ability to detect improper payments in China, India, and Kuwait.

In October 2013, Stryker agreed to pay more than $13 million to settle charges it violated the FCPA after its subsidiaries in Argentina, Greece, Mexico, Poland, and Romania made illicit payments.

Adrianne Appel writes regulatory news, policy, and trends for Compliance Week. She previously reported about policy developments for Bloomberg Law and Bloomberg Government.

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