• Appian

The Foreign Corrupt Practices Act (FCPA) and the Physician Payment Sunshine Act (Sunshine Act) create an enormous compliance burden and expose pharmaceutical companies to financial risk. Steep Penalties for Non-Compliance Almost 1/2 of the total FCPA enforcement by the SEC happened in the last four years $18 million average per violation of FCPA 2 Sunshine Act Up to $1 million maximum annual penalty for failure to correctly report a financial transaction 3
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