London-based medical device company Smith & Nephew PLC has been charged with violating the Foreign Corrupt Practices Act (FCPA) as a result of its U.S. and German subsidiaries bribed public doctors in Greece for more than a decade to win business. It is alleged that its subsidiaries used a distributor to create a slush fund to make illicit payments to public doctors employed by government hospitals or agencies in Greece. On paper, it seemed as though Smith & Nephew’s subsidiaries were paying for marketing services, but no services were actually performed. The scheme basically created off-shore funds that were not subject to Greek taxes to pay bribes to public doctors to purchase Smith & Nephew products.
Smith & Nephew PLC with Foreign Bribery