Stryker to pay $7.8M to settle SEC Foreign Corrupt Practices Act violation charge: 5 things to know

Written by Laura Dyrda | October 01, 2018 | Print  |

On Sept. 28, the Securities and Exchange Commission charged Stryker with violating the books and records and internal accounting controls provisions for the Foreign Corrupt Practices Act.


Here are five things two know:

1. Last week marked the second time the SEC has brought FCPA action against Stryker, and the company agreed to settle the charges by paying a $7.8 million penalty.

2. The SEC found Stryker's internal accounting controls weren't sufficient to detect the risk of improper payments of product sales in India, China and Kuwait. The company's India-based subsidiary failed to maintain complete and accurate books and records, according to an SEC statement.

3. Under the agreement, Stryker paid the settlement without admitting or denying the SEC findings. The company consented to the entry of an order requiring Stryker to cease and desist from committing similar violations in addition to the penalty payment.

4. Stryker must now retain an independent compliance consultant to review and evaluate independent controls, record-keeping and anti-corruption policies and procedures that relate to dealers, agents, distributors, sub-distributors and other third parties.

5. In 2013, Stryker settled FCPA violation charges, paying $2.5 million in a penalty as well as more than $7.5 million in disgorgement of ill-gotten gains and $2.2 million in interest.

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