Alexion FCPA Violations: Lessons Learned (Part II of II)

Michael Volkov comments on the implications of the SEC's enforcement action against Alexion Pharmaceutical, noting that the drug and medical device industries are easy targets for prosecutors to investigate and prosecute for foreign bribery, for various reasons: foreign healthcare professionals are commonly “foreign officials” under the FCPA, they are usually underpaid and expecting of additional compensation, and there are nonetheless a number of legitimate reasons to engage with them.