This enforcement action involved multiple corruption schemes in multiple countries, some continuing to occur after the company had self-disclosed to the DOJ. The company agreed to pay a total criminal penalty of $84,715,273. Fresenius Medical Care AG & Co. KGaA (FMC) settled a related FCPA matter with the US Securities and Exchange Commission (SEC) and paid $147 million in disgorgement and prejudgment interest to the SEC, which the DOJ credited in its resolution, bringing the total amount paid by FMC to over $231 million. Due to its conduct, the company did not qualify for a Declination under the FCPA Corporate Enforcement Policy; however, the company was afforded a reduction of 40 percent below the low end of the US Sentencing Guidelines fine range. FMC achieved the 40% reduction through an extensive remediation program and robust cooperation with the DOJ during the investigation.