Three Strikes For Stryker

In a May 2nd SEC filing, Stryker Corporation, a Michigan-based medical device manufacturer, said that it is “currently investigating whether certain business activities in a foreign country violated provisions of the Foreign Corrupt Practices Act.” This latest revelation comes after two prior FCPA violations. Stryker paid $13 million in 2013 to resolve SEC allegations that it bribed doctors and administrators at government-controlled hospitals in Argentina, Greece, Mexico, Poland, and Romania. In 2018, the company paid a $7.8 million penalty for FCPA books, records, and accounting controls offenses in India, China, and Kuwait. In the latest disclosure, Stryker said it has been contacted by the SEC and DOJ and has “engaged outside counsel to conduct” the new investigation. In a statement, the company said it was unable to predict the outcome or potential impact of the latest investigation.