For more information on DPA mobile systems and other FCPA-related agreements, see Gibson Dunn`s FCPA update at the end of 2019. In the first six months of 2019, the DOJ has already concluded 21 DPAs and NPAs with corporate offenders. This means the department is on track to reach previous peak years in 2007 and 2010, when the number of preliminary agreements for the whole year exceeded 40. Zimmer and Biomet (even a spin-off of Bristol-Myers Squibb) merged in 2015. But in 2007, Zimmer and Biomet were separate medical device companies, and the DOJ accused them both, along with three other medical device companies, of using inappropriate payments to trick surgeons into using the companies` hip and knee replacements. Both companies have entered into 18-month DPAs with the DOJ.  The 10 public interest factors are: “a.
September 16, 2021