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Enforcement Action Dataset

 

Initiation Date:    10/24/2013  Information

Prosecuting Agency:    U.S. Securities and Exchange Commission

Type of Action:    SEC Administrative Proceeding

Docket or Case Number:    3-15587

Name of Prosecuting Attorneys:    Unknown

US Assisting Agencies:   Unknown

Foreign Enforcement Action/Investigation:   Unknown

Foreign Assisting Agencies:   Unknown

Origin of the Proceeding:    SEC investigation

Whistleblower:    Unknown

Case Status:    Resolved


Summary  Information

Stryker Corporation was a Michigan corporation with its principal executive offices in Kalamazoo, Michigan. Stryker manufactured and distributed medical devices and products in more than 100 countries around the world. Its common stock was registered with the SEC and listed on the New York Stock Exchange.

From about August 2003 to February 2008, Stryker made approximately $2.2 million in unlawful payments to various government employees including public health care professionals in Mexico, Poland, Romania, Argentina, and Greece. Stryker incorrectly described these expenses in the company’s books and records as legitimate consulting and service contracts, travel expenses, charitable donations, or commissions, when in fact the payments were improperly made by Stryker to obtain or retain business. Stryker earned approximately $7.5 million in illicit profits as a result of these payments.

On October 24, 2013, the SEC instituted an administrative proceeding against Stryker ordering it to cease and desist its violations of the books & records and internal controls provisions of the FCPA. Under the terms of the proceeding, Stryker was also ordered to pay disgorgement of $7,502,635 plus prejudgment interest of $2,280,888 and a civil monetary penalty of $3,500,000.

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