SEC Fine Repeat FCPA Breach

On Sep. 28, SEC fined Stryker medical $7.8mn FCPA violations.

• For second time Stryker medical device has been charged with FCPA failures.

Alleged Violations

• Company violated books, records and internal accounting controls provisions.
• Internal accounting controls did not detect risk of improper payment in sales
  in India, Chin, and Kuwait, and Indian subsidiary did not keep proper records.

Sanctions

• Stryker agreed to settle FCPA failure charges of and pay $7.8 million penalty.
• Follows SEC Oct. 2017 FCPA settlement with Stryker, for $13.2mn.