Today’s email basket contains an SEC announcement of its settlement of Foreign Corrupt Practices Act charges against medical equipment seller Stryker Corporation, involving world-wide corrupt payments to foreign government individuals in an effort to garner business contracts. 

The tab?  About $13.2M in fines including interest of more than $2M!  And some of the matters complained of date back to 2003; the SEC has a long memory.

I have written before about intense SEC and DOJ interest in bribes of offshore government employees to gain business, noting it is a slippery slope.  Many overseas companies are indeed government-owned one way or another, and “grease payments” to individuals affiliated with these companies constitute government bribes.  This is particularly sensitive in, and less obvious in, the life science area where overseas hospitals, for example, are often government institutions.

That said, it is hard to imagine a more uninspired set of alleged facts.  In one Strkyer episode, a payment allegedly was laundered through an offshore lawfirm, booked as a legal fee although no services were provided, and the law firm just forwarded the money.  In another case, a $200,000 donation allegedly was made to a public university in Greece to fund a lab for a public hospital doctor.

My favorite: Stryker allegedly sent a director of a public Polish hospital on a paid business trip– with spouse –including 6 days in New York City, two Boradway shows and five days in that vertibable hub of life science deals:  Aruba.

Stryker’s profits on these deals were about $7.5M.  The net: negative almost $6M, and on top of that all those legal fees….