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Enforcement Action Dataset

 

Initiation Date:    09/28/2018  Information

Prosecuting Agency:    U.S. Securities and Exchange Commission

Type of Action:    SEC Administrative Proceeding

Docket or Case Number:    3-18853

Name of Prosecuting Attorneys:   

  • William Martin, SEC New York Regional Office
  • Brenda Wai Ming Chang, SEC New York Regional Office
  • Thomas P. Smith Jr., SEC New York Regional Office
  • Devon Anthony Brown, SEC Headquarters
  • Andrew Shirley, SEC Headquarters
  • Brian O. Quinn, SEC Headquarters
  • Sanjay Wadhwa, SEC Headquarters

US Assisting Agencies:   Unknown

Foreign Enforcement Action/Investigation:   Unknown

Foreign Assisting Agencies:   Unknown

Origin of the Proceeding:    Unknown

Whistleblower:    Unknown

Case Status:    Resolved


Summary  Information

Stryker Corporation was a Michigan corporation that manufactured and distributed medical devices and products in more than 100 countries around the world. The company's common stock was registed with the SEC and traded on the New York Stock Exchange. Stryker operated out of several countries through wholly-owned subsidiaries, including Stryker India in India, Stryker China in China, and EMEA Supply Chain Services B.V in the Middle East.

According to the documents in this case, Stryker’s internal controls were insufficient to detect and prevent the risk of improper payments to public health care professionals in India, China, and Kuwait. Additionally, Stryker India failed to maintain adequate books and records. Stryker had previously been the subject of an SEC administrative action in 2013 alleging a series of improper payments in several other countries.

In a settled administrative proceeding initiated on September 28, 2018, the SEC issued a cease and desist order against Stryker. Under the terms of the order, the SEC ordered Stryker to cease and desist violations of the books & records and internal controls provisions of the FCPA, to pay a civil fine of $7.8 million, and to retain an independent compliance monitor for a term of one year.

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