01Jul
Novartis and Alcon FCPA Enforcement Action: Lessons Learned (Part III of III)
At the outset, Novartis is “lucky” – the settlement is relatively positive, despite its 2016 SEC enforcement action in China. Given Novartis weak culture of compliance (if anything, a better description may be a culture of non-compliance) and its status as a recidivist, Novartis could have been slammed with a stiffer enforcement action, including assignment of an independent corporate compliance monitor and a higher penalty. ...
By:
Michael Volkov
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