Lessons Learned from Novartis FCPA

General

Novartis and Alcon FCPA Enforcement Action: Lessons Learned (Part III of III)

The Novartis and Alcon FCPA enforcement action is chock full of interesting issues.  See Novartis DPA Here , Alcon DPA Here and SEC Novartis Order Here. 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