X
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
Source Url: https://www.jdsupra.com/legalnews/novartis-and-alcon-fcpa-enforcement-13538/

Related

Even Among Friends, Office Affair Is OK ... Until It Isn’t

A consensual affair between a superior and subordinate can advance to a quid pro quo harassment clai...

Read More >

A “Fair Reading” Of The FLSA Exempts Paralegals From Overtime Pay

Should highly compensated paralegals (likely more experienced paralegals) receive overtime pay? The ...

Read More >

FTC Revises Hart-Scott-Rodino Thresholds for 2020

On January 28, 2020, the Federal Trade Commission announced revised notification thresholds pursuant...

Read More >

When Harry's Met Schick: How Nascent Competition Theory Got in the Way of a Proposed Acquisition

On Feb. 3, the Federal Trade Commission (FTC) challenged Edgewell Personal Care’s proposed $1.37 bi...

Read More >

Immigration and Customs Enforcement ("ICE") Audits: Are You Ready?

As you may have heard, Immigration and Customs Enforcement (“ICE”) plans to begin the previously p...

Read More >

CCPA is Here – Is Your Privacy Notice Ready?

Last year towards the end of May, a barrage of emails and pop-ups informed online users about how co...

Read More >