United States v. Johnson & Johnson (Depuy)
United States District Court for the District of Columbia
No. 11-CR-00099 (2011)

- Written by Rich Walter, JD
Facts
The United States government accused the Johnson & Johnson corporation (J&J) and its subsidiary, Depuy, Inc. (defendants), of violating the Foreign Corrupt Practices Act (FCPA). The government offered to defer prosecution if J&J agreed to strengthen its existing FCPA compliance program by adopting additional (1) corporate anticorruption policies; (2) compliance standards and procedures to be followed by J&J directors, employees, foreign agents, and foreign business partners; (3) compliance oversight duties for senior executives; (4) training and certification programs and other mechanisms for communicating J&J’s anticorruption policies, standards, and procedures to J&J directors, employees, agents, and business partners; (5) measures for reporting violations of anticorruption policies, standards, and procedures; (6) disciplinary procedures for such violations; (7) due-diligence requirements pertaining to retention and oversight of agents and business partners; (8) standard anticorruption contract provisions; and (9) periodic testing to evaluate the effectiveness of J&J’s FCPA compliance program.
Rule of Law
Issue
Holding and Reasoning ()
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