This client alert discusses MilliporeSigma's underlying conduct; how MilliporeSigma handled its internal investigation, voluntary self-disclosure to, and cooperation with, the DOJ; the factors that the DOJ considered when deciding not to charge MilliporeSigma; and how companies should consider handling similar situations. Background From July 2016 to May 2023, Gregory Muñoz, a MilliporeSigma salesperson, conspired to falsify export documents and sell heavily discounted biochemical products from MilliporeSigma to buyers in China. Muñoz falsely represented to MilliporeSigma that his co-conspirator, Pen Yu, was affiliated with a Florida university's biology research lab. In reliance on these false statements, MilliporeSigma gave Yu millions of dollars' worth of discounts for his orders of biochemical products. In exchange, Yu gave Muñoz bribes totaling over $100,000.