Fresenius Medical FCPA

General

2019 FCPA Enforcement Highlights (Part II of III)

In a record year, there are bound to be numerous interesting enforcement actions and principles. I picked out a few to highlight. It is surprising to say the least that DOJ continues to return large enforcement actions against a number of global companies. You would think after the last ten

General

Fresenius Medical’s Bribery Conduct Precludes Declination (Part II of III)

Fresenius Medical came close to earning a declination under the FCPA Corporate Enforcement Policy. Unfortunately, Fresenius’ effort fell short -- but it came close. Fresenius Medical operates more than 3700 dialysis clinics worldwide and has 37 production sites in various countries. Fresenius’ relationship with third-party agents and distributors created significant