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 | Enforcement Action Dataset

Stanford Foreign Corrupt Practices Act Clearinghouse a Collaboration with Sullivan & Cromwell LLP

Enforcement Action Dataset

 
In Re Micrus Corp. · Micrus' Involvement in Multiple Countries from 2002 to 2004

Case Information

In Re Micrus Corp.

Related FCPA Matter:   Micrus' Involvement in Multiple Countries from 2002 to 2004 Information

Case Information

Initiation Date:    02/28/2005  Information

Prosecuting Agency:    U.S. Department of Justice

Type of Action:    DOJ Criminal Proceeding

Docket or Case Number:    N/A

Court:    N/A

Name of Prosecuting Attorneys:   

  • Joshua R. Hochberg, Chief, Fraud Section, Criminal Division
  • Mark F. Mendelsohn, Deputy Chief, Fraud Section, Criminal Division
  • Christopher A. Wray, Assistant Attorney General
  • Patrick M. Donley, Senior Litigation Counsel, Fraud Section, Criminal Division

US Assisting Agencies:   Unknown

Foreign Enforcement Action/Investigation:   Unknown

Foreign Assisting Agencies:   Unknown

Origin of the Proceeding:    Voluntary disclosure

Whistleblower:    Unknown

Case Status:    Resolved


Summary  Information

Micrus Corporation was a privately held company based in Sunnyvale, California that developed and sold, in domestic and foreign markets, medical devices known as embolic coils which allow minimally invasive treatment of neurovascular diseases such as intracranial aneurysms.

Micrus violated the FCPA by paying doctors at public hostpitals in France, Turkey, Spain, and Germany approximately $105,000 to influence them to purchase medical devices known as embolic coils. The payments were disguised in Micrus' books and records as stock options, honorariums and commissions. In addition, Micrus paid $250,000 to doctors without obtaining the necessary prior administrative or legal approval as required under the laws of the relevant foreign jurisdiction.

On February 28, 2005, Micrus entered into a non-prosecution agreement with the DOJ. As part of the non-prosecution agreement, Micrus agreed to pay a civil penalty of $450,000, accept responsibility for its misconduct, and adopt a compliance program with an independent compliance monitor.


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