Last week, the SEC announced a settlement of an FCPA enforcement action for $12 million against Mead Johnson Nutrition for payment of bribes in China to health care professionals at state-owned hospitals. Mead Johnson's illegal payments were intended to increase referrals by Chinese physicians and healthcare officials of Mead Johnson products, and obtain access to marketing and personal information about expectant and recent mothers. Over a five-year period, Mead Johnson paid approximately $2 million in illegal payments to Chinese healthcare professionals. Mead Johnson funded the bribes by giving its distributors allowance funds that marketed and sold Mead Johnson's products. While the money was awarded to Mead Johnson's distributors, employees exerted control over the spending and use of the funds. The SEC's case is yet another in the healthcare industry built on the finding that physicians and other medical staff at state-owned hospitals are "foreign officials" for purposes of the FCPA.