An SEC investigation found that the schemes spanned a period of years and involved the transfer of money, gifts, and other things of value to health care professionals, which led to millions of dollars in increased sales of the company's pharmaceutical products to China’s state health institutions. The participants included certain complicit sales and marketing managers within the company's China-based subsidiaries. The company failed to devise and maintain a sufficient system of internal accounting controls and lacked an effective anti-corruption compliance program to detect and prevent these schemes. As a result, the improper payments were not accurately reflected in the company's books and records.
To read the entire SEC Press Release please follow this link: $20M for FCPA Violations