Pfizer DPA Part II – Enhanced Compliance Obligations and Corporate Compliance Obligations

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Last week I began an exploration of the Pfizer Deferred Prosecution Agreement (DPA) which was announced last week by the Department of Justice (DOJ) in connection with its settlement of Foreign Corrupt Practices Act (FCPA) violations. In Part I, I reviewed the Corporate Compliance Obligations, Attachment C.1. Today we review the Enhanced Compliance Obligations, Attachment C.2 and Corporate Reporting Obligation, Attachment C.3, which Pfizer agreed to implement and operate under. In Part III, I will discuss some of the implications raised by the Pfizer DPA for the compliance practitioner.

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Published In: General Business Updates, International Trade Updates, Securities Updates, Mergers & Acquisitions Updates, Franchise Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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