Its final settlement ultimately constituted the largest ever FCPA resolution involving a health care entity. 3 Similar improper payments to foreign officials in China resulted in multi-million dollar FCPA settlements with UK-based pharmaceutical companies such as GlaxoSmithKline and AstraZeneca PLC, as well as the Swiss-based Novartis LC. 4 While a full report and breakdown of these enforcement actions can be found on the SEC's website, the common thread is that each health care entity conducted business or sales in a foreign market by improperly bribing local officials or government employees. 5 As the globalization of the health care industry amplifies and our international medical markets become further integrated, medical device distributors and pharmaceutical manufacturers must maintain strict compliance programs regarding anti-bribery regulations and must be aware of the broad extra-territorial application of laws such as the FCPA.