Richard L. Cassin Publisher and Editor
Andy Spalding Senior Editor
Jessica Tillipman Senior Editor
Elizabeth K. Spahn Contributing Editor
Eric Carlson Contributing Editor
Benjamin Kessler Contributing Editor
Michael Kuria Contributing Editor
Thomas Fox Contributing Editor
Philip Fitzgerald Contributing Editor
Marc Alain Bohn Contributing Editor
Michael Scher Contributing Editor
Bill Waite Contributing Editor
Shruti J. Shah Contributing Editor
Dr. Henry Wong Contributing Editor
Russell A. Stamets Contributing Editor
Mark R. Friedman Contributing Editor
Andrew Reichardt Editorial Intern
Global Contagion Report | Thursday, March 21, 2013 at 6:28AM Country: Philippines
Company Involved: Universal Entertainment Corp.
Industry: Consumer Services
Industry Subsector: Gambling
FCPA Jobs | Tuesday, March 5, 2013 at 7:18AM Title: Head of Corporate Governance Research
Company: Quest
Location: Manila, Philippines
Benjamin Kessler | Wednesday, September 5, 2012 at 4:02AM 
In editorials directly addressing Bureau of Internal Revenue Commissioner Kim Henares, two Philippines-based journalists urged the government to exercise "extreme caution" before entertaining a contract bid from Chinese laser technology company Huagong Tech Company Ltd.
Richard L. Cassin | Monday, February 20, 2012 at 2:28AM Wynn Resorts Ltd said Sunday its board asked a director to resign and already redeemed his 20% stake in the company after an internal investigation found numerous violations by him of the Foreign Corrupt Practices Act.
Richard L. Cassin | Wednesday, November 16, 2011 at 10:58AM President Obama meets tomorrow on Bali, Indonesia with the heads of state from ASEAN -- the Association of Southeast Asian Nations.
Richard L. Cassin | Wednesday, November 16, 2011 at 7:28AM In its quarterly report filed with the SEC last week, pharma giant Pfizer Inc said it has reached agreement in principle with the SEC and DOJ to resolve 'improper payment' matters outside the United States.
Richard L. Cassin | Friday, May 13, 2011 at 7:46AM More than half the journalists murdered in the line of duty were working to expose corruption.
Richard L. Cassin | Wednesday, January 26, 2011 at 6:59AM A quick test for stability is to check how long the leader has hung on, and how corrupt his or her country is perceived to be by the rest of the world. It's inexact but can give clues about what might happen.
Richard L. Cassin | Monday, March 8, 2010 at 7:10AM 
As reported Friday, one of the 22 shot-show defendants, Daniel Alvirez, is expected to plead guilty soon to charges of conspiracy to violate the Foreign Corrupt Practices Act. The government's two-count superseding information alleged that he plotted to bribe defense officials in Africa and the Republic of Georgia.
What to expect now? We asked someone familiar with the evidence, who requested anonymity. Here's what he or she told us:
The government's video and audio tapes are of good quality and the confidential informant, Richard Bistrong, should be an effective witness despite some baggage. Overall, the cases appear to be strong and supported by ample evidence.
There are indications of more foreign bribery involving the military-equipment industry; the allegations in the first 16 indictments (available here) and the superseding information may be the tip of the iceberg.
The Justice Department is seeking to build bigger cases against some current defendants. It may also indict other individuals.
Investigators could also be looking at involvement by some well-known industry leaders -- an Indian military-equipment supplier, three U.S. public companies, and two large private security contractors among them.
Countries and governments involved may include not just Georgia (mentioned in the superseding information) but also Peru, Mexico, Saudi Arabia, Guatemala, the Philippines, Colombia, and others. Representatives from some of the countries could be targeted by the Justice Department.
Richard L. Cassin | Wednesday, September 2, 2009 at 8:58PM 
Will drug makers be the target of the next industry-wide Foreign Corrupt Practices Act investigation, following in the footsteps of the oil and gas services companies and orthopedic device makers? It's possible. Their sales practices are in the news a lot these days. And amid the healthcare debate, drug-company behavior anywhere invites attention in Washington and beyond.
Remember the orthopedic device makers? Like Pfizer this week and Eli Lilly earlier this year, they resolved enforcement actions based on illegal domestic sales practices. Soon after, most of them disclosed that the DOJ and SEC were looking into their overseas marketing methods for any FCPA offenses. Those investigations are ongoing. See our post Tough Medicine For Medical Device Makers.
Here's some recent pharma news:
◆ Pfizer's $2.3 billion civil and criminal penalty for unlawful prescription drug promotions.
The New York Times reported here that: "To promote the drugs, authorities said Pfizer invited doctors to consultant meetings at resort locations, paying their expenses and providing perks. 'They were entertained with golf, massages, and other activities,' said Mike Loucks, the U.S. attorney in Massachusetts." (In January, Eli Lilly paid $1.42 billion to settle off-label marketing charges.) New York attorney general Andrew Cuomo said yesterday, "Pfizer's corrupt practices went so far as sending physicians on exotic junkets as well as wining and dining health care professionals to persuade them to prescribe the company's drugs for patients in taxpayer-funded programs." Using similar sales techniques with doctors at government-owned hospitals overseas could violate the FCPA.
◆ Forest Laboratories' document, “Lexapro Fiscal 2004 Marketing Plan.”
It's an 88-page extract from the company's strategic plan for turning the drug into a high-priced bestseller. The document was recently made public by the Senate’s Special Committee on Aging. Forest's plan includes tactics such as a ghostwriting program -- like the one discussed in our post Helping Doctors Cheat. The Lexapro marketing blueprint is aimed at the U.S. domestic market. Some tactics described in the plan, if directed overseas, could have FCPA compliance implications. A copy of Forest's marketing plan for Lexapro can be downloaded here.
◆ Pfizer's foreign lobbying practices.
In July, a senator in the Philippines issued a press release here that accused Pfizer of using illegal tactics to block legislation aimed at lowering drug costs. Senator Mar Roxas said he had written a letter to the U.S. Justice Department requesting an FCPA investigation into Pfizer's practices. He accused the company of offering the country's health secretary "discount cards" in exchange for not implementing the retail drug-price law.
In his letter to Mark Mendelsohn, the Deputy Chief of the Fraud Section at the DOJ's Criminal Division, the senator said,
I understand that your good office is responsible for the enforcement of the anti-bribery provisions of the Foreign Corrupt Practices Act, which makes it unlawful to make a corrupt payment to a foreign national for the purpose of obtaining or retaining business. Thus, any assistance that your office can extend in looking into the allegations of bribery against Pfizer will be invaluable to our efforts of lowering the cost of healthcare, starting with the prices of medicines, in our country. At this juncture, I wish to note that the actions of Pfizer may constitute the offense of corruption of public officials under Philippine laws, as defined in the Philippine Revised Penal Code.Pfizer disputes the senator's charges. It bought full-page ads in Philippines newspapers saying, "We categorically deny this allegation and consider this a grave affront to our reputation … We have always sought to provide wider access to our high quality medicines."
Thanks to Cody Worthington for the link to the Philippine senator's press release.
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