Late September saw the release of the Alere Inc. (Alere) SEC enforcement action which contained an FCPA component as well as penalties related to the company’s failures around revenue recognition. Alere agreed to pay more than $13MM to settle charges that it bribed foreign officials and committed accounting fraud to meet revenue targets. Of that $13MM, the company agreed to disgorge $3.3MM, interest of about $495,000 and pay a penalty of $9.2MM. It was at the opposite end of a spectrum from the Telia settlement of $965MM.
