On August 7, 2012, the Securities and Exchange Commission (the “SEC”) charged Pfizer Inc. with violating the Foreign Corrupt Practices Act (“FCPA”).  The SEC Complaint alleges that employees and agents of Pfizer’s subsidiaries in Bulgaria, China, Croatia, Czech Republic, Italy, Kazakhstan, Russia, and Serbia made improper payments to foreign officials to obtain regulatory and formulary approvals, sales, and increased prescriptions for the company’s pharmaceutical products. The Complaint further alleged that there were efforts to conceal the bribery by improperly recording the transactions in accounting records as legitimate expenses for promotional activities, marketing, training, travel and entertainment, clinical trials, freight, conferences, and advertising.

The SEC filed a separate Complaint charging another pharmaceutical company that Pfizer acquired several years ago – Wyeth LLC – with its own FCPA violations. Pfizer and Wyeth agreed to separate settlements in which they will pay more than $45 million combined to settle their respective FCPA charges.