Novartis Pays $25 Million to Settle Allegations of FCPA Violations in China

On March 23, 2016, Novartis AG (“Novartis”) agreed to pay $25 million to settle civil charges with the Securities and Exchange Commission (“SEC”) alleging that it violated the Foreign Corrupt Practices Act (the “FCPA”) by paying bribes to healthcare professionals (“HCPs”) in China from 2009 to 2013 to increase sales. Employees and managers of its two China-based subsidiaries attempted to hide the improper payments by using complicit third party agents and by improperly recording them as legitimate expenses for travel and entertainment, conferences, educational events, and medical studies. These books and records were later consolidated into the financial reports of Novartis, which is listed on the New York Stock Exchange. This conduct resulted in violations of the books and records and internal accounting controls provisions of the FCPA.