Pfizer H.C.P. received a penalty reduction as a result of Pfizer Inc.`s collaboration in the ongoing investigation of other companies and individuals. In addition to the $15 million fine, the agreement requires Pfizer Inc. to continue to conduct strict internal controls and cooperate fully with the Division. Or is it another example of the fact that a company is obliged by the government (at risk of lawsuits for omission) to participate in fishing expeditions (if the company has already gone fishing), only to resume fishing, thus constituting an unlimited and unlimited transfer of the shareholder`s assets to FCPA Inc.? In 1997, Pfizer H.C.P. entered into a consulting contract in Croatia with a dual role client – a prominent Croatian physician and professor of internal medicine at a state-funded university. According to the DOJ, the Croatian doctor also had “influence over the registration and reimbursement decisions of Pfizer products that are marketed and sold in the country” and participated at various times in government committees that made national decisions regarding the approval and authorization of marketing authorities. The recent action under the Foreign Corrupt Practices Act against Pfizer is remarkable in many respects. (See below for a previous article that details some remarkable aspects). It is also worth noting the “enhanced compliance requirements” that Pfizer must meet in accordance with the provisions of the deferred order maintenance agreement. The agreement recognizes timely voluntary disclosure by Pfizer`s parent company H.C.P., Pfizer Inc.; A thorough and comprehensive review of underlying and related behaviours; The company`s significant cooperation with the division and the SEC; and Pfizer Inc.`s early and significant remediation efforts and substantial and ongoing improvements to its global compliance procedures to combat corruption. As part of the resolution, the department today submitted a double criminal investigation, accused by Pfizer H.C.P.
of conspiracy and violation of the FCPA in connection with improper payments to government officials, including public regulators and health professionals in Bulgaria, Croatia, Kazakhstan and Russia. The division and Pfizer H.C.P. agreed to resolve the investigation with a deferred prosecution agreement. The information and the adjourned law enforcement agreement were filed today at the U.S. District Court in the District of Columbia. Diligence, including anti-corruption assessments, of distributors in high-risk markets for corruption. According to DOJ, Pfizer H.C.P. Kazakhstan has entered into an exclusive distribution agreement with a Kazakh company, valued at at least $500,000. According to the DOJ, all or part of the value of the agreement should be shared with Kazakh government officials.