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Internal Controls Under the FCPA

Most Foreign Corrupt Practices Act (FCPA) practitioners understand the requirement for a compliance policy under the FCPA. However many practitioners, particularly lawyers practicing in the compliance field, do not understand the requirement for proper Internal Controls. Generally speaking, Internal...

Johnson & Johnson, DePuy Pay $76.9M To Settle Foreign Bribery Claims

(Mealey's) - Johnson & Johnson (J&J) and subsidiary DePuy International Ltd. will pay $76.9 million to resolve criminal and civil allegations in the United States and in the United Kingdom that they paid kickbacks to doctors in Greece, Poland, Romania and Iraq to use the companies'...

Johnson & Johnson and DePuy Settle Claims They Paid Kickbacks to Doctors

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Johnson & Johnson Deferred Prosecution Agreement-Part II: Compliance Program Best Practices

Yesterday we reviewed the background facts of the Johnson & Johnson (J&J) Deferred Prosecution Agreement (DPA) and the issue of self-reporting. In this posting we will review some of specific compliance program best practices which Johnson & Johnson agreed to implement. I. Attachment...

Johnson & Johnson Becomes the Newest Member of the FCPA Top 10 Settlements List

Current trends in FCPA enforcement are evident in the latest settlement with Johnson & Johnson. U.S. v. Depuy, Inc. , (D.D.C. Filed April 8, 2011); SEC v. Johnson & Johnson , Civil Action No. 1:11-cv-00686 (D.D.C. Filed April 8, 2011). To resolve the case with DOJ and the SEC the company...