An Overview of the Foreign Corrupt Practices Act for Healthcare Companies
Epstein Becker & Green P.C., Washington D.C.
The globalization of healthcare has resulted in U.S. healthcare companies working with government agencies and government healthcare systems in foreign countries, the officers, employees, and agents of which may be classified as “foreign officials” under the Foreign Corrupt Practices Act (FCPA). This business relationship with government- owned and government-controlled entities and foreign officials creates a potentially high level of exposure to violations of the FCPA. As recent enforcement actions and investigations demonstrate, the healthcare industry is not exempt from prosecution for FCPA violations.
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