High FCPA Risks in Medical Devices

In a recent public announcement, Johnson & Johnson disclosed that it may have violated the Foreign Corrupt Practices Act ("FCPA") and had reported potential violations to the Department of Justice and the Securities and Exchange Commission ("SEC"). Johnson & Johnson’s disclosure highlights the risks of FCPA violations for the medical device industry. It also reflects a broader trend of increased FCPA enforcement, as do recent cases involving multi-million dollar fines....