By Eric Kraeutler and Alison Tanchyk
Published in Criminal Litigation, Volume 11, Number 2, Winter 2011
The pharmaceutical and medical device industries long have been target of the Department of Justice (DOJ), state attorneys general, and whistleblowers, all of whom have had repeated success in securing billions of dollars in criminal and civil actions. Those industries will remain targets because many long- standing practices—including gifts, honoraria, consulting arrangements, education grants, advisory councils, speaker programs, and product samples—present as great a risk under the Foreign Corrupt Practices Act.