August 30, 2016
These proceedings arise out of violations of the internal controls and recordkeeping provisions of the Foreign Corrupt Practices Act (the “FCPA”) by AZN and its wholly-owned subsidiaries in China and Russia. Through at least 2010, AZN failed to devise and maintain a sufficient system of internal accounting controls relating to the interactions of its China and Russia subsidiaries with government officials, the vast majority of whom were health care providers (“HCPs”), at state-owned and state-controlled entities in China and Russia. Sales and marketing staff, along with multiple levels of management at the two AZN subsidiaries, designed and authorized several schemes to make improper payments of gifts, conference support, travel, cash and other benefits to HCPs to reward or influence their purchases of AZN pharmaceuticals.
Respondent shall, within fourteen (14) days of the entry of this Order, pay disgorgement of $4,325,000, which represents profits gained as a result of the conduct described herein, prejudgment interest of $822,000, and a civil money penalty of $375,000 to the Securities and Exchange Commission for transfer to the general fund of the United States Treasury.