A worldwide internal investigation that Teva Pharmaceutical Industries began three years ago into possible violations of the Foreign Corrupt Practices Act continues to expand in scope—and further appears to have found evidence of wrongdoing, the company stated in a recent securities filing.
As Compliance Week previously reported, Teva’s investigation, with assistance from outside counsel, began in 2012 after the Israel-based company received subpoenas and informal document requests from the Securities and Exchange Commission and the Department of Justice in connection with possible FCPA violations in certain countries.
In the course of that investigation, which is continuing, Teva previously said it had identified certain business practices and transactions in Russia, certain European countries, certain Latin American countries that “could potentially rise" to the level of FCPA violations, as well as violations of local law. In its latest securities filing, dated Feb. 9, Teva added that it has identified certain business practices and transactions in “other countries in which it conducts business,” and that these business practices “likely” constitute FCPA violations, as well as violations of local law.
Furthermore, in connection with its investigation, Teva said it also has become aware that “affiliates in certain countries under investigation provided to local authorities inaccurate or altered information relating to marketing or promotional practices.” The company said it has brought, and continues to bring, these issues to the attention of the SEC and Justice Department.
Teva added, however, that it “cannot predict at this time the impact on the company as a result of these matters, which may include material fines in amounts that are not currently estimable, limitations on the company’s conduct, the imposition of a compliance monitor and/or other civil and criminal penalties.”