There are some strong indicators to suggest that 2016 is on track to be a real banner year regarding Foreign Corrupt Practices Act (“FCPA”) enforcement and qui tam actions. One of the most notable indicators is that FCPA enforcement for 2016 is on track to exceed actions for 2015. Additionally, newly unsealed qui tam cases show the FCPA focus on health care and hi-tech companies and the enforcement actions involving other countries, in particular, China is growing. This year is also an introduction to the DOJ’s pilot program for self- disclosure, corporate transparency, and continued support for whistleblower rewards.
Although all the data is not in yet, based on what we can see so far, in comparison to FY 2015, FY 2016 is on track to exceed the previous year’s Foreign Corrupt Practices Act (“FCPA”) and False Claims (FAC) enforcement levels. This is particularly true when qui tam cases and whistleblower awards are factored in.
Read Full Article in the November 2016 Issue of Life Science Compliance Update