The Eli Lilly FCPA Enforcement Action-Lessons Learned

The Lilly FCPA enforcement action, as laid out in the SEC Complaint, provides the compliance practitioner with solid information which can be used in a variety of ways to strengthen an anti-corruption/anti-bribery compliance program. First and foremost is the detailed discussion the different types of bribery schemes that were engaged in throughout the company. If your sales model is an employee based sales force, a distributor model with discounts off your list price or commission based third party agents, the Lilly FCPA enforcement See more +

The Lilly FCPA enforcement action, as laid out in the SEC Complaint, provides the compliance practitioner with solid information which can be used in a variety of ways to strengthen an anti-corruption/anti-bribery compliance program. First and foremost is the detailed discussion the different types of bribery schemes that were engaged in throughout the company. If your sales model is an employee based sales force, a distributor model with discounts off your list price or commission based third party agents, the Lilly FCPA enforcement action provides you with questions that you can ask to see if you company has FCPA issues to investigate. The SEC Complaint also details the internal controls failures which Lilly sustained and led to the enforcement action. There is also significant and detailed information on what you might look at or do in your compliance program to answer Paul McNulty’s three questions if you are in the position to deal with the SEC or DOJ on a FCPA issue. See less -